Jeffrey Naimon

Jeffrey Naimon

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)

Redlining Cases In 2015 And A New Discrimination Standard

Limited access to mortgage credit for credit-impaired and low- and moderate-income (and, therefore, disproportionately minority) borrowers has become a significant public policy challenge in the post-financial crisis era....more

1/8/2016 - Banking Sector DOJ Fair Housing Act (FHA) Fair Lending HMDA HUD Mortgage Lenders Qualified Mortgage Rule Race Discrimination Real Estate Market Redlining

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)

Vendor Management in 2015 and Beyond

With evolving regulatory expectations and increased enforcement exposure, financial institutions are under more scrutiny than ever. Nowhere is this more evident than in the management and oversight of service providers. When...more

1/5/2016 - CFPB Financial Institutions Risk Management Third-Party Service Provider Vendors

Citizen, Soldier, Small-Business Owner? Commercial Lending and The Servicemembers Civil Relief Act

The Servicemembers Civil Relief Act, 50 U.S.C.A. § 3901, provides certain protections to military service members regarding their financial obligations. The act applies to virtually every type of debt that a service member...more

12/28/2015 - Banking Sector Consumer Lenders Financial Institutions SCRA

Landlords, Leases And The Servicemembers Civil Relief Act

As President Obama slows the drawdown of troops overseas — and as the nation expands its fight against ISIS — a growing number of service members will seek the benefits and protections of a nearly century-old law that...more

11/19/2015 - Eviction Landlords Lease Termination Residential Leases SCRA

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

Special Alert: Third Circuit Gives FTC Green Light to Continue Enforcing Corporate Data Security

Last week, the U.S. Court of Appeals for the Third Circuit affirmed the Federal Trade Commission’s authority to hold companies accountable for their data security practices under Section 5 of the FTC Act (15 U.S.C. § 45(a)),...more

9/1/2015 - Appeals Credit Cards Cyber Attacks Cyber Crimes Cyber Threats Cybersecurity Data Breach Plans Data Privacy Data Protection Data Security Debit Cards FTC FTC Act FTC v Wyndham Gramm-Leach-Blilely Act Hackers Section 5 Unfair or Deceptive Trade Practices Wyndham

Special Alert: Second Circuit Will Not Rehear Madden Decision That Threatens to Upset Secondary Credit Markets

Two months ago we issued a Special Alert regarding the decision of the Court of Appeals for the Second Circuit in Madden v. Midland Funding, LLC, which held that a nonbank entity taking assignment of debts originated by a...more

8/14/2015 - Consumer Lenders FDIC Financial Institutions Loan Agreements Midland Funding National Bank Act Nonbank Firms Petition for Writ of Certiorari Preemption SCOTUS Usury

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: Second Circuit Decision Threatens To Upset Secondary Credit Markets

The Second Circuit Court of Appeals’ recent decision in Madden v. Midland Funding, LLC held that a nonbank entity taking assignment of debts originated by a national bank is not entitled to protection under the National Bank...more

6/12/2015 - Credit Agreements Financial Institutions Loans Midland Funding National Bank Act Nonbank Firms Usury

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: 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

A New Balancing Act: The DOJ Provides New Direction Regarding the SCRA's Interest Rate Benefit

When Congress reenacted the Servicemembers’ Civil Relief Act (“SCRA”) in 2003, Congress designed the SCRA to balance the interests of active duty servicemembers and their creditors, as it had done under the SCRA’s predecessor...more

2/11/2015 - Consent Order Consumer Lenders Financial Institutions Interest Rates Lenders Military Service Members SCRA

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

Caveat Emptor or Caveat Vendor? The Evolution of Unfairness in Federal Consumer Protection Law

Under the Federal Trade Commission’s original interpretation of unfair or deceptive acts or practices law, financial institutions could feel some sense of security that, if they provided a consumer with a clear understanding...more

1/29/2015 - CFPB China Data Brokers Data Controller FCRA Fiduciary Duty Financial Institutions FTC Mobile Devices Mobile Payments Prudential Regulation Authority Shadow Banking Unfair or Deceptive Trade Practices

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)

BuckleySandler Files Amici Curiae Brief on Behalf of Industry Groups in Supreme Court TILA Case

On September 17, BuckleySandler filed an amici curiae brief on behalf of six industry associations in a Supreme Court case addressing the right to rescind a transaction under the Truth in Lending Act (TILA). In Jesinoski v....more

9/25/2014 - Borrowers Jesinoski v Countrywide Rescission SCOTUS 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

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