Benjamin Klubes

Benjamin Klubes

BuckleySandler LLP

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Latest Publications


Special Alert: CFPB Finalizes Rule to Oversee Nonbank Auto Lenders

On June 10, the CFPB issued its final rule to oversee “larger participant” nonbank auto finance companies. Although the CFPB received significant feedback during the comment period, the final rule is nearly identical to that...more

6/12/2015 - Automotive Loans CFPB Debt Collection ECOA Federal Register Financial Institutions Financial Markets Lenders Nonbank Firms Securitization

Special Alert: CFPB Issues Statement On TRID Enforcement

On June 3, CFPB Director Cordray responded to requests from industry and members of Congress for delayed enforcement of the Bureau’s TILA-RESPA Integrated Disclosure (“TRID”) rule, which will take effect for applications...more

6/4/2015 - CFPB RESPA Richard Cordray TILA-RESPA Integrated Disclosure Rule (TRID) Truth in Lending Act (TILA)

CFPB’s New ‘‘Responsible Conduct’’ Guidelines: Will They Incentivize Greater Self-Reporting And Self-Regulation By Consumer...

On June 25, 2013, the Consumer Financial Protection Bureau (CFPB or the Bureau) issued CFPB Bulletin 2013-6, titled ‘‘Responsible Business Conduct: Self-Policing, Self-Reporting, Remediation, and Cooperation.’’ The CFPB...more

1/23/2014 - CFPB Compliance Enforcement Self-Regulatory Organizations Self-Reporting

Another Court Affirms DOJ Financial Fraud Strategy

On Sept. 24, 2013, Judge Jesse Furman in the Southern District of New York released his widely anticipated decision allowing the U.S. Department of Justice’s False Claims Act and Financial Institutions Reform, Recovery and...more

10/11/2013 - DOJ Fair Housing Act (FHA) False Claims Act (FCA) FIRREA Fraud HUD Mortgage Loan Originators Mortgage Servicers Wells Fargo WSLA

Under the microscope: Back to the future of TILA

"Sparked by perceived increases in deceptive practices and widespread confusion about the nature and cost of credit, the Truth in Lending Act of 1968 emerged from much the same sentiment that this year prompted the passage of...more


New Home Mortgage Disclosure Act Pricing Data: The Next Enforcement and Litigation Front for Lenders

Now required to publicly report pricing information on home mortgage loans, lenders can expect class-action litigation asserting disparate-impact discrimination claims. Class action lawyers also will scrutinize and likely use...more


Risk Management in Mortgage Loan Servicing and Collection

It has become increasingly evident that federal and state regulatory and law enforcement agencies, including the Federal Trade Commission, as well as the federal and state bank regulatory agencies, rating agencies, investors,...more


Increased Fair Lending Enforcement Activity

Over the course of the past several years, fair lending enforcement has emerged beyond Department of Justice investigations concerning discriminatory treatment of minorities with respect to real estate secured loans. Today,...more


Protecting Confidentiality of Internal Reviews by Financial Services Providers

Consumer financial services companies are facing rapidly growing risk management and litigation issues involving compliance with laws and regulations prohibiting protected class discrimination, unfair and deceptive trade...more


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