What Happened? On July 10, 2024, the Consumer Financial Protection Bureau (CFPB or Bureau) proposed a rule to amend provisions of its Mortgage Servicing Rules to significantly revamp requirements relating to borrowers...more
7/23/2024
/ Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Delinquent Borrowers ,
Financial Institutions ,
Financial Services Industry ,
Foreclosure ,
Loss Mitigation ,
Mortgage Lenders ,
Mortgage Servicers ,
Mortgage Servicing Rules ,
Mortgages ,
Notice Requirements ,
Proposed Rules ,
Regulation X
What Happened? On June 3, 2024, the Consumer Financial Protection Bureau (CFPB or Bureau) issued its Registry of Nonbank Covered Persons Subject to Certain Agency and Court Orders Final Rule (the Final Rule), a 486-page rule...more
6/19/2024
/ Compliance ,
Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Dodd-Frank ,
Final Rules ,
Financial Institutions ,
Financial Services Industry ,
Non-Bank Lenders ,
Recordkeeping Requirements ,
Regulatory Oversight ,
Reporting Requirements
What Happened? Both the FHA and VA have established new loss mitigation options to provide payment reduction to delinquent borrowers. On February 21, 2024, the Federal Housing Administration (“FHA”) within the U.S....more
What Happened? On March 13, 2024, Fannie Mae issued Servicing Guide Announcement (SVC-2024-02) (the “Announcement”), which announced, among other things, updates to Fannie Mae’s Loan Modification Agreement (Form 3179), with...more
What Happened? On March 4, 2024, Ginnie Mae issued All Participant Memorandum (APM) 24-02 to impose a new cybersecurity incident notification requirement. Ginnie Mae has also amended its Mortgage-Backed Securities Guide to...more
What Happened? On February 27, 2024, the California Department of Financial Protection and Innovation (the Department) entered into a public consent order with a company that provides consumer financial services to...more
What Happened? On January 24, 2024, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a proposed rule that would prohibit covered financial institutions from imposing a nonsufficient funds (NSF) fee when...more
What Happened? On January 11, 2024, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) issued two separate advisory opinions interpreting consumer reporting agencies’ (“CRAs”) obligations under the Fair Credit...more
What Happened? Earlier this week, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) released a blog post touting its 2023 successes in safeguarding “household financial stability” through the levying of fines and...more
A&B Abstract: On December 20, 2023, the Department of Veterans Affairs (VA) issued Circular 26-23-27 (the “Circular”) to remind holders and servicers of VA-guaranteed loans about their obligation to process assumptions and...more
As we reflect on the previous year and look toward the new year, we thought you’d appreciate our top 20 most-read Consumer Finance ABstract posts from 2023...more
1/10/2024
/ Consumer Financial Products ,
Consumer Financial Protection Act (CFPA) ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Disclosure Requirements ,
Financial Institutions ,
Financial Services Industry ,
FinTech ,
Mortgage Lenders ,
Mortgage Servicers ,
NYDFS
A&B Abstract: According to a recent edition of Inside Mortgage Finance, correspondent lending is the only lending channel that posted gains in Q3 2023. While it is always nice to see gains, it should also serve as a reminder...more
A&B Abstract: On November 3, 2023 the Financial Stability Oversight Council (hereinafter “FSOC” or “Council”) unanimously approved final versions of: (1) the new Analytic Framework for Financial Stability Risk...more
A&B Abstract: On October 24, 2023, the U.S. Department of Housing and Urban Development (“HUD”) published, for public comment, a Federal Register Notice (“Proposed Notice”) to implement changes to the Federal housing...more
Welcome to the latest edition of the Spectrum, covering hot-topic issues in the structured finance markets in the U.S. and UK. This edition features a new year for a new UCC Article 12, a farewell to LIBOR, and an appraisal...more
2/28/2023
/ Appraisal ,
Asset Management ,
Banking Sector ,
Bias ,
Blockchain ,
Commercial Loans ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
Cryptocurrency ,
Digital Assets ,
Fair Housing Act (FHA) ,
Financial Institutions ,
Financial Markets ,
Financial Services Industry ,
FinTech ,
Foreclosure ,
Libor ,
Non-Bank Lenders ,
Proposed Rules ,
Secured Overnight Funding Rate (SOFR)
A&B Abstract: On January 30, 2023, President Biden informed Congress that the COVID-19 National Emergency (the “COVID Emergency”) will be extended beyond March 1, 2023, but that he anticipates terminating the national...more
2/27/2023
/ CARES Act ,
Compliance ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Consumer Lenders ,
FHFA ,
Financial Services Industry ,
Forbearance Agreements ,
HUD ,
Mortgage Lenders ,
Mortgage Servicers ,
Mortgages ,
Popular
A&B ABstract: Effective on approval by Governor Kathy Hochul on December 30, 2022, New York Assembly Bill 7737b – the Foreclosure Abuse Prevention Act (the “Act”) became law....more
A&B ABstract: On January 11, 2023, the Consumer Financial Protection Bureau (the “CFPB” or “Bureau”) announced a proposed rule to establish a public registry and require nonbanks supervised by the agency to register their...more
A&B ABstract: On December 12, 2022, the Consumer Financial Protection Bureau (CFPB) announced a proposed rule to require certain non-banks to register with the agency when they become subject to a public written order or...more
A&B ABstract: Mortgage assumptions – where a buyer assumes the existing mortgage loan of a seller – have fluctuated in popularity since the 1980s....more
A&B ABstract: The Consumer Financial Protection Bureau (“CFPB” or “Bureau”) has moved to clarify its regulatory authority at a time when the economic climate is ripe for a resurgence in HELOC lending. In an amicus brief...more
A&B Abstract: On November 16, 2022, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) released its Fall 2022 Supervisory Highlights (Issue 28) (the “Supervisory Highlights”), which, among other things, announces...more
A&B Abstract: On August 10, 2022, the Federal Housing Finance Agency (“FHFA”) announced that Fannie Mae and Freddie Mac (the “GSEs”) will require mortgage servicers to obtain and maintain fair lending data on their loans,...more
A&B Abstract: The Nationwide Multistate Licensing System & Registry (NMLS) Policy Committee is inviting comments on the NMLS Disclosure Questions Proposal. The comment period is now open and runs until August 22. Among other...more
A&B Abstract: On May 2, 2022, Georgia Governor Brian Kemp signed HB 891 and SB 470 into law. HB 891, effective July 1, 2022, updates various laws enforced by the Georgia Department of Banking and Finance (the “Department”)...more