Donald Lampe

Donald Lampe

Morrison & Foerster LLP

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CFPB Publishes Results of eClosing Pilot Program

On August 5, the CFPB released a 90-page report summarizing the results of its eClosing pilot program, a research initiative launched in April 2014 to explore whether electronic closing processes offer measurable benefits to...more

8/19/2015 - Borrowers CFPB E-Signatures eClosing Pilot Program Electronic Filing Lenders Mortgages Technology TILA-RESPA Integrated Disclosure Rule (TRID)

CFPB Examination Resource Guide

CFPB has explained to industry participants what to expect in examinationss, both in terms of exam process and covered laws & regs. SUPERVISION AND EXAMINATION MANUAL – VERSION 2.0 First issued in 10/2011, revised &...more

7/31/2015 - CFPB ECOA FDCPA HOEPA Mortgage Loan Originators Mortgage Servicers Mortgages Resource Guide RESPA TILA UDAAP

The CFPB & UDAAP: A “Know It When You See It” Standard?

The Consumer Financial Protection Bureau’s (CFPB) exercise of its sweeping authority to prohibit unfair, deceptive, and abusive acts or practices (UDAAP) continues to command the attention of financial institutions and...more

7/29/2015 - CFPB Enforcement Actions Financial Institutions Financial Services Industry Richard Cordray UDAAP

MBa Compliance Essentials - CFPB EXAMINATIONS: What We Know Now

In This Presentation: - What is “Supervision”? - CFPB’s Examination Principles - Supervision is a Process - Types of Examinations - Preparing for the Examination - EXAM...more

7/2/2015 - Banks CFPB Chief Compliance Officers Consumer Lenders Examination Priorities Industry Examinations Nonbank Firms Supervision

TILA-RESPA Combined Disclosures: The Executive Perspective October 29, 2014

In This Presentation: - ½-Way Point & What We Will Cover - NEW RISK ENVIRONMENT - THINKING ABOUT RISKS FOR 2015 - Business Challenges and Your Bottom Line - What is Behind TRID? - Communications...more

6/25/2015 - CFPB Mortgage Lenders RESPA TILA TILA-RESPA Integrated Disclosure Rule (TRID)

Mortgage Servicing Transfers: Meeting the Operational and Regulatory Demands

In This Presentation: - The “Old” Ways - New Federal Framework for Servicers - Dodd-Frank Act - National Mortgage Settlement - CFPB at the Center - CFPB Regulations (Reg X) - CFPB...more

5/29/2015 - CFPB Dodd-Frank Mortgage Servicing Rules National Mortgage Settlement Remedies RESPA TILA Transfers

CFPB Announces Final Policy Statement to Share Consumer Complaint Narratives, and Issues an RFI Seeking Comment on a Proposed...

On March 19, 2015, the Consumer Financial Protection Bureau (“CFPB”) announced the issuance of a Final Policy Statement (“Policy Statement”) that expands its Consumer Complaint Database (“Database”) to allow consumers to...more

4/6/2015 - CFPB Consumer Complaint System Consumer Financial Products Policy Statement Request For Information

Supreme Court Allows Agencies to Reinterpret the Law at Their Discretion

In a decision published on March 9, 2015, the Supreme Court ended the D.C. Circuit Court’s Paralyzed Veterans doctrine, which required administrative agencies to utilize the Administrative Procedure Act’s (APA)...more

4/1/2015 - Administrative Procedure Act Notice and Comment Paralyzed Veterans Doctrine Perez v Mortage Bankers Assoc Rulemaking Process SCOTUS Statutory Interpretation

Legislation Introduced to Modify CFPB Structure: Will It Gain Traction?

Earlier this month, a year after the House passed a bill to change the structure of the Consumer Financial Protection Bureau (CFPB), Rep. Randy Neugebauer (R-Tex.) again introduced legislation that would modify the structure...more

3/18/2015 - Administrative Appointments CFPB Proposed Legislation

The CFPB & UDAAP: A ‘Know It When You See It’ Standard?

The Consumer Financial Protection Bureau’s (CFPB) continued and expanded reliance on its sweeping authority to prohibit unfair, deceptive, and abusive acts or practices (UDAAP) continues to command the attention of financial...more

3/12/2015 - Banking Sector CFPB Consumer Lenders Enforcement Statistics Financial Institutions Richard Cordray UDAAP

Bad Day for NewDay: CFPB Section 8 Enforcement Continues

On February 10, 2015, the Consumer Financial Protection Bureau (“CFPB”) added another company to its litany of alleged Real Estate Settlement Procedures Act (“RESPA”) Section 8 offenders (Michigan Title, PHH Corporation, New...more

2/20/2015 - Advertising CFPB Enforcement Enforcement Actions Kickbacks LLC Referral Fees RESPA Section 8 UDAAP Unfair or Deceptive Trade Practices Veterans

A Friendly Reminder from CFPB on Confidential Supervisory Information

On January 27, 2015, the Consumer Financial Protection Bureau (“CFPB”) issued a Compliance Bulletin 2015-1 (the “Bulletin”) reminding supervised financial institutions about regulatory requirements surrounding Confidential...more

1/30/2015 - CFPB Confidential Supervisory Information Financial Institutions Non-Disclosure Agreement

The CFPB 2015 Forecast: Continued Cloudiness, Thunderstorms Likely

This will be a busy year at the Consumer Financial Protection Bureau (CFPB), and that certainly means it will be a busy year for financial institutions as well. In addition to exercising its supervisory and enforcement...more

1/26/2015 - Automotive Loans Banking Sector CFPB Consumer Lenders Debt Collection ECOA Financial Institutions HMDA Integrated Disclosures Mortgage Lenders Mortgages Prepaid Payment Products Proposed Regulation Regulation C RESPA Supervision TILA UDAAP

The CFPB & UDAAP: A “Know It When You See It” Standard?

The Consumer Financial Protection Bureau’s (CFPB) continued and expanded reliance on its sweeping authority to prohibit unfair, deceptive, and abusive acts or practices (UDAAP) continues to command the attention of financial...more

1/22/2015 - Banking Sector CFPB Enforcement Actions Financial Institutions Richard Cordray UDAAP

TILA-RESPA Integrated Disclosure Rule Updates and Additional

On September 8, 2014, the CFPB issued an updated Small-Entity Compliance Guide to the new TILA-RESPA integrated disclosure rule. This updates the original guide issued in April 2014 to provide additional resources on the rule...more

11/7/2014 - CFPB Disclosure Requirements Market Participants RESPA TILA

CFPB Proposes Issuing No-Action Letters: Innovation at Too Much Cost and Uncertainty?

On October 10, 2014, the CFPB issued notice of and requested public comment on a proposed policy allowing CFPB staff to issue no-action letters (NALs) for “innovative financial products or services that substantially benefit...more

10/17/2014 - CFPB Consumer Financial Products Enforcement Innovation No-Action Letters Public Comment

FTC Targeting Deceptive Advertising of Mortgage Lead Generators

The Federal Trade Commission’s (FTC) recent complaint against Intermundo Media, LLC (Intermundo) alleging deceptive marketing tactics under the FTC Act and Mortgage Acts and Practices – Advertising Rule (MAP Rule)...more

10/14/2014 - FTC Interest Rates MAP Rule Marketing Mortgage Loan Originators Unfair or Deceptive Trade Practices Warning Letters

CFPB as HUD: Another Section 8 Consent Order Displays CFPB’s RESPA Approach

In a recent Real Estate Settlement Procedures Act (“RESPA”) enforcement action, the Consumer Financial Protection Bureau (“CFPB”) negotiated a consent order with Lighthouse Title, Inc. (“Lighthouse”) for alleged violations of...more

10/2/2014 - Anti-Kickback Statute CFPB Consent Order HUD Mortgages RESPA

SID is Coming, But Who Will Be Ready to Greet Him?

Congress directed the CFPB to enact a rule that would combine mandatory mortgage-related Truth in Lending Act (TILA) and Real Estate Settlement Procedures Act (RESPA) consumer disclosures into one “single integrated...more

10/1/2014 - CFPB Mortgages New Regulations RESPA TILA

What’s Unfair is Unfair: Repeal of Reg AA May Have Little Practical Effect

The Federal Reserve Board (Board) issued a notice of proposed rulemaking on August 22, 2014 (Notice) for the repeal of Regulation AA, which is the Board’s credit practices rule prohibiting certain unfair or deceptive acts and...more

9/10/2014 - CFPB Compliance FDIC Federal Reserve FTC NCUA OCC Regulation AA

No RESPA Respite - Continued

The CFPB continues to crack down on basic RESPA violations. On August 12, 2014, the CFPB announced yet another Consent Order with alleged violations of RESPA. In this case, an on-line retail mortgage company, the company’s...more

8/20/2014 - CFPB Consent Order Disclosure Requirements Internet Retailers Mortgages RESPA Secured Lenders

The RESPA Respite Is Over

RESPA Section 8 enforcement is back. It was in abeyance during the transition of RESPA enforcement from HUD to the CFPB over the last few years. In fact, the last announced HUD Section 8 settlement dates from almost three...more

6/24/2014 - Enforcement Enforcement Actions HUD Mortgages RESPA TILA

The CFPB & UDAAP: A “Know It When You See It” Standard?

Institutions regulated by the Consumer Financial Protection Bureau (CFPB) and subject to its enforcement authority are dealing with of the agency’s sweeping authority to prohibit unfair, deceptive, and abusive acts or...more

6/13/2014 - CFPB Enforcement Actions Investigations Richard Cordray UDAAP

Housing Finance Reform

Efforts to address housing finance reform are starting to heat up, although the finish line is still probably a long way off. Fannie Mae and Freddie Mac remain in conservatorship, even though they are making money, and the...more

4/29/2014 - Fannie Mae Freddie Mac Housing Finance Reform Mortgages

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