Jeffrey Naimon

Jeffrey Naimon

BuckleySandler LLP

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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 TILA-RESPA Integrated Disclosure Rule (TRID)

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 Marketing Services Agreement 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 TILA-RESPA Integrated Disclosure Rule (TRID)

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 Sallie Mae 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 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 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 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 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 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

Infobytes Special Alert: VA Adopts Its QM Rule

On May 9, 2014, the Department of Veterans Affairs (the “VA”) issued an interim final rule defining what constitutes a “qualified mortgage” (“QM”) for purposes of the loans it guarantees, insures, or originates. The VA stated...more

5/16/2014 - CFPB Department of Veterans Affairs Military Service Members Mortgages Qualified Mortgage Rule Veterans

Special Alert: CFPB Proposes Amendments To Mortgage Rules

On April 30, the Consumer Financial Protection Bureau (CFPB or Bureau) proposed targeted amendments to the Dodd-Frank Act mortgage rules that took effect in January 2014. Comments are due 30 days after publication of the...more

5/1/2014 - CFPB Dodd-Frank Mortgages Proposed Amendments

Lenity, Chevron Deference And Consumer Protection Laws

Several federal statutes, including the Real Estate Settlement Procedures Act (“RESPA”), the Truth in Lending Act (“TILA”) and the Servicemembers Civil Relief Act (“SCRA”) permit the government to seek either civil or...more

1/17/2014 - Chevron Chevron Deference Enforcement Actions HUD Mortgages Real Estate Market RESPA SCRA TILA

Infobytes Special Alert: HUD Adopts Its Own QM Rule

On December 11, 2013, the Department of Housing and Urban Development (“HUD”) issued a final rule defining what constitutes a “qualified mortgage” (“QM”) for purposes of loans insured by the Federal Housing Administration...more

12/18/2013 - CFPB FHA HUD Mortgages Qualified Mortgage Rule

Infobytes Special Alert: CFPB Finalizes Rule Combining TILA And RESPA Mortgage Disclosures

On November 20, 2013, the CFPB finalized its long-awaited rule combining the mortgage disclosures consumers receive under the Truth in Lending Act (“TILA”) and the Real Estate Settlement Procedures Act (“RESPA”). For more...more

12/2/2013 - CFPB Dodd-Frank HUD Mortgage Servicing Rules Mortgages RESPA TILA

Special Alert: OCC Updates Third-Party Risk Management Guidance

On October 30, the OCC issued Bulletin 2013-29 to update guidance relating to third-party risk management. The Bulletin, which rescinds OCC Bulletin 2001-47 and OCC Advisory Letter 2000-9, requires banks and federal savings...more

11/4/2013 - Affiliates Banks Contract Drafting Due Diligence Joint Venture OCC Payment Processors Risk Management Subsidiaries

Special Alert: Agencies Issue Joint Statement On Fair Lending Compliance And The CFPB’s ATR/QM Rule

On October 22, the CFPB, the OCC, the FDIC, the Federal Reserve Board, and the NCUA (collectively, the Agencies) issued a joint statement (Interagency Statement) in response to inquiries from creditors concerning their...more

10/24/2013 - Ability-to-Repay CFPB Compliance DOJ ECOA FDIC Federal Reserve HUD Mortgages NCUA OCC Qualified Mortgage Rule Regulation B

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