Benjamin Olson

Benjamin Olson

BuckleySandler LLP

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Special Alert: CFPB Plans to Propose TRID Amendments in July

Director Cordray announced yesterday in a letter to industry trade groups that the CFPB has "begun drafting a Notice of Proposed Rulemaking (NPRM) on the Know Before You Owe Rule.” However, contrary to some reports, the...more

4/29/2016 - Banking Sector CFPB Mortgages NPRM Proposed Amendments TILA-RESPA Integrated Disclosure Rule (TRID)

TRID Liability Will Be A Dominant Issue In 2016

Oct. 3, 2015, was a watershed moment for the mortgage origination industry and the Consumer Financial Protection Bureau. On that date, the CFPB’s long-awaited Know Before You Owe: TILA-RESPA Integrated Disclosure (TRID) rule...more

1/14/2016 - CFPB Disclosure Requirements Mortgage Lenders Mortgages TILA-RESPA Integrated Disclosure Rule (TRID)

Special Alert: CFPB Director Opines on TRID Liability

On December 29, 2015, CFPB Director Richard Cordray issued a letter in response to concerns raised by the Mortgage Bankers Association regarding violations of the CFPB’s new TILA-RESPA Integrated Disclosure (“TRID”) rule,...more

1/6/2016 - CFPB Disclosure Requirements Policy Violations TILA-RESPA Integrated Disclosure Rule (TRID)

The CFPB’s Mortgage Originations Agenda in 2016

Now more than ever, financial services firms need to proactively focus on issues of concern identified by the CFPB and ensure that they are engaged in industry best practices that are clearly identified and carefully...more

12/16/2015 - Best Practices CFPB Financial Services Industry Mortgage Loan Originators TILA-RESPA Integrated Disclosure Rule (TRID) UDAAP

Special Alert: CFPB Adopts Significant Expansion of HMDA Reporting Requirements

On October 15, the Consumer Financial Protection Bureau (the CFPB or Bureau) issued a final rule that will expand the scope of the Home Mortgage Disclosure Act (HMDA) data reporting requirements while seeking to streamline...more

10/19/2015 - Banking Sector Banks CFPB Compliance Consumer Lenders Disclosure Requirements Dodd-Frank Fannie Mae FCRA FDIC Final Rules Financial Institutions Freddie Mac HELOC HMDA HOEPA Mortgage Lenders Mortgage Loan Originators Mortgage Servicers Mortgages OCC Reporting Requirements TILA-RESPA Integrated Disclosure Rule (TRID)

Special Alert: CFPB Issues Guidance Regarding Marketing Services Agreements

On October 8, 2015, the Consumer Financial Protection Bureau (“CFPB”) published a compliance bulletin providing guidance to mortgage industry participants regarding the permissibility of marketing services agreements (“MSAs”)...more

10/12/2015 - CFPB Compliance Debt Settlement Services Financial Institutions Kickbacks Marketing Services Agreements Mortgage Servicers Popular Referral Fees Regulatory Oversight Residential Real Estate Market RESPA Whistleblowers

Spotlight on the Military Lending Act, Part 2: Planning for Compliance

Compliance with the revised Department of Defense (“DoD”) regulations under the Military Lending Act (“MLA”) is not mandatory until October 3, 2016 or, for most credit cards, until October 3, 2017. However, as the recent...more

8/24/2015 - Automotive Industry Automotive Loans Compliance Consumer Lenders Department of Defense (DOD) Disclosure Requirements Dodd-Frank Financial Institutions Lenders Loans Military Lending Act Mortgage Lenders Mortgage Servicers Mortgages Personal Property Regulation Z Residential Real Estate Market Truth in Lending Act (TILA)

Spotlight on the Military Lending Act: Did the Final Rule Improve on the Proposal?

On July 22, 2015, the Department of Defense (“Department”) released its final rule amending the regulations that implement the Military Lending Act (“MLA”), which means that a wider range of credit products—including open-end...more

8/4/2015 - Banking Sector Banks Borrowers CARD Act Compliance Consumer Credit Protection Credit Cards Department of Defense (DOD) Financial Institutions Lenders Military Lending Act Military Service Members Truth in Lending Act (TILA)

Special Alert: CFPB Launches First Monthly Complaint Report Providing Snapshot of Consumer Trends

On June 16, 2015, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) launched the first in a new series of monthly complaint reports highlighting key trends from consumer complaints submitted to the CFPB....more

7/17/2015 - Banking Sector Banks CFPB Consumer Complaint System Financial Institutions

Special Alert: CFPB Issues Proposal to Delay TRID Rule Until October 3

The CFPB issued a proposed rule today to delay the effective date of the TILA-RESPA Integrated Disclosure (“TRID”) rule, including all amendments, from August 1 to October 3, 2015. The proposed delayed effective date is two...more

6/25/2015 - CFPB Effective Date Proposed Regulation RESPA TILA-RESPA Integrated Disclosure Rule (TRID) Truth in Lending Act (TILA)

Special Alert: CFPB Will Propose to Delay TRID Rule Until October 1

Two weeks after declining requests from industry and members of Congress for delayed enforcement of the TILA-RESPA Integrated Disclosure (“TRID”) rule, the CFPB announced today that it will be issuing a proposed amendment to...more

6/18/2015 - CFPB Delays Proposed Amendments Public Comment Richard Cordray TILA-RESPA Integrated Disclosure Rule (TRID)

Special Alert: CFPB Consent Order Applies Loan Originator Compensation Rule to Marketing Services Agreements

On Friday, the CFPB announced a consent order against Guarantee Mortgage Corporation, resolving allegations that the company paid loan originators based on the terms of their mortgage loans in violation of the Loan Originator...more

6/9/2015 - CFPB Consent Order Enforcement Actions Loan Originator Compensation Rule Mortgage Lenders Mortgage Loan Originators Mortgages RESPA

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)

Special Alert: CFPB Releases Outline Of Proposed Rule For Payday, Vehicle Title, And Similar Loans

On March 26, the CFPB announced that it is considering proposing a rule to “end payday debt traps” and released several related documents, including a fact sheet and an outline of the proposal that will be presented to a...more

3/30/2015 - CFPB Consumer Lenders Payday Loans Proposed Regulation SBREFA Title Loans

Special Alert: USDA-RHS Proposes Its Own QM Rule

On March 5, 2015, the USDA-RHS released a proposed rule to amend the regulations for the Single Family Housing Guaranteed Loan Program (SFHGLP) to provide that a loan guaranteed by USDA-RHS is a QM if it meets certain...more

3/17/2015 - Mortgage Lenders Mortgage Loan Originators Mortgages Single Family Housing

Special Alert Update: OCC Revises Guidance Regarding Consumer Protection Requirements to Overdraft Lines and Protection Services

On March 6, 2015, the OCC issued its revised “Deposit-Related Credit” booklet (“DRC booklet”) of the Comptroller’s Handbook, which replaced the “Deposit-Related Consumer Credit” booklet issued on February 11, 2015 (previously...more

3/11/2015 - Banks Consumer Financial Products Deposit Accounts Guidance Update OCC Overdraft Fees

Special Alert: OCC Guidance Applies Consumer Protection Requirements to Overdraft Lines and Protection Services

On February 11, 2015, the OCC issued the “Deposit-Related Consumer Credit” booklet of the Comptroller’s Handbook, which replaced the “Check Credit” booklet. The booklet provides updated guidance and examination procedures...more

2/17/2015 - Banks CFPB Consumer Financial Products Guidance Update OCC Overdraft Fees Regulation Z Truth in Lending Act (TILA)

Special Alert: CFPB States Supervisory Obligations Trump Nondisclosure Agreements

On January 27, the CFPB issued Compliance Bulletin 2015-01 to remind supervised financial institutions of their obligations concerning the disclosure of confidential supervisory information (CSI) to the CFPB and to third...more

1/29/2015 - CFPB Confidential Information Disclosure Requirements Financial Institutions Non-Disclosure Agreement Nonbank Firms Supervision Third-Party

Special Alert: CFPB Finalizes Amendments to TILA-RESPA Integrated Mortgage Disclosures

On January 20, 2015, the CFPB finalized amendments to the TILA-RESPA Integrated Disclosure (“TRID”) rule that make a number of amendments, clarifications, and corrections, including...more

1/22/2015 - CFPB Integrated Disclosures Mortgages RESPA Truth in Lending Act (TILA)

SPECIAL ALERT: CFPB Finalizes Points-And-Fees Cure And Other Mortgage Rule Amendments

Last week, the CFPB finalized an important amendment to its ATR / QM Rule that provides a mechanism for curing points-and-fees overages on qualified mortgage (“QM”) loans, as well as more minor amendments to its mortgage...more

10/29/2014 - CFPB Mortgages Qualified Mortgage Rule RESPA Truth in Lending Act (TILA)

Special Alert: Proposed Amendments to the TILA-RESPA Integrated Disclosure (“TRID”) Rule, Transcript of CFPB Webinar on the Loan...

BuckleySandler is pleased to announce our new TILA-RESPA Integrated Disclosure (“TRID”) Resource Center. The TRID Resource Center is a one-stop shop for TRID issues, providing access to BuckleySandler’s analysis of the TRID...more

10/16/2014 - CFPB Disclosure Requirements Loans Mortgages RESPA Truth in Lending Act (TILA)

Infobytes Special Alert: CFPB Bulletin Re-Emphasizes Focus On Mortgage Servicing Transfers

On August 19, 2014, the CFPB issued Bulletin 2014-01 to address “potential risks to consumers that may arise in connection with transfers of residential mortgage servicing rights.” The bulletin, which is the latest in a...more

8/22/2014 - CFPB Mortgage Servicers Mortgage Servicing Rules Mortgages Real Estate Transfers Transfers

Special Alert: CFPB Issues Guidance On Supervision And Enforcement Of Mini-Correspondent Lenders

This afternoon, the CFPB issued policy guidance on supervision and enforcement considerations relevant to mortgage brokers transitioning to mini-correspondent lenders. The CFPB states that it “has become aware of increased...more

7/14/2014 - CFPB Enforcement Enforcement Actions Lenders Mortgages

InfoBytes Special Alert: CFPB Guidance States That Successors Are Not Subject To The ATR/QM Rule

On July 8, 2014, the CFPB issued an interpretive rule stating that the addition of a successor as an obligor on a mortgage does not trigger the Ability-to-Repay/Qualified Mortgage Rule (“ATR/QM Rule”) requirements if the...more

7/10/2014 - Beneficiaries CFPB Creditors Mortgages Regulation Z Successors Truth in Lending Act (TILA)

Pom v. Coke Will Impact Financial Services Too

Law 360, New York (June 23, 2014, 11:22 AM ET)--Legal and compliance departments, take note: the U.S. Supreme Court’s recent decision in Pom Wonderful LLC v.Coca-Cola Co. confirms that even i fan institution’s conduct meets...more

7/1/2014 - Advertising CFPB Coca Cola False Advertising FDCA FDIC Food Labeling FTC Lanham Act NLEA OCC POM Wonderful POM Wonderful v Coca Cola SCOTUS UDAAP

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