Jeffrey Naimon

Jeffrey Naimon

BuckleySandler LLP

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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

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

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: 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

Infobytes Special Alert: CFPB Issues Mortgage Servicing Rule Amendments And Guidance Addressing Conflicts With Bankruptcy And Debt...

On October 15, 2013, the Consumer Financial Protection Bureau (“CFPB”) issued an interim final rule amending certain provisions of its mortgage servicing rules and making technical changes to other January 2013 mortgage rules...more

10/17/2013 - CFPB Consumer Bankruptcy Debt Collection FDCPA Mortgage Servicers Mortgages

SPECIAL ALERT: CFPB Announces First HMDA Enforcement Action, Issues HMDA Guidance

On October 9, the Consumer Financial Protection Bureau (CFPB or Bureau) announced it had assessed civil money penalties totaling $459,000 against two financial institutions—one bank and one nonbank—after examinations...more

10/11/2013 - CFPB Civil Monetary Penalty Enforcement Actions HMDA Mortgages Reporting Requirements

Infobytes Special Alert: HUD Proposes Its Own QM Rule

On September 27, 2013, the Department of Housing and Urban Development (“HUD”) released a proposal defining what constitutes a “qualified mortgage” (“QM”) for purposes of loans insured by the Federal Housing Administration...more

10/3/2013 - Ability-to-Repay CFPB FHA HUD Mortgages Qualified Mortgage Rule TILA

Infobytes Special Alert: CFPB Finalizes Additional Amendments To The 2013 Mortgage Rules

On September 13, 2013, the Consumer Financial Protection Bureau (“CFPB”) finalized another set of amendments (the “Amendments”) to its January 2013 mortgage rules. Whereas previous amendments focused largely on the...more

9/18/2013 - Ability-to-Repay CFPB Mortgage Loan Originators Mortgages Proposed Amendments Qualified Mortgage Rule

HUD Sets Stage For FCA Claims Against Fund Recipients

The Fair Housing Act requires agencies to administer their programs and activities relating to housing and urban development “affirmatively to further” fair housing. Recipients of U.S. Department of Housing and Urban...more

8/2/2013 - Fair Housing Act False Claims Act Housing Market HUD Mortgages

InfoBytes Special Alert: CFPB Proposes Additional Amendments To Mortgage Rules - June 26, 2013

On June 24, 2013, the Consumer Financial Protection Bureau ("CFPB") issued another set of proposed amendments to its January 2013 mortgage rules....more

6/27/2013 - Ability-to-Repay CFPB Fees Foreclosure Loan Originator Compensation Rule Loss Mitigation Mortgage Servicing Rules Mortgages Qualified Mortgage Rule

InfoBytes Special Alert: CFPB Finalizes Amendments To The Ability-To-Repay/Qualified Mortgage Rule

Yesterday afternoon, the Consumer Financial Protection Bureau (“Bureau”) finalized important amendments (the “Amendments”) to its ability-to-repay/qualified mortgage rule (the “Rule”) concerning the extent to which loan...more

5/31/2013 - Ability-to-Repay CFPB Creditors Loans Mortgage Brokers Mortgage Loan Originators Mortgages Qualified Mortgage Rule

Special Alert: CFPB Issues Final Rule Requiring Provision Of Copies Of Appraisals And Valuations To Credit Applicants

On January 18, the Consumer Financial Protection Bureau (CFPB) issued a final rule that implements amendments made by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) to the Equal Credit...more

1/31/2013 - Appraisal CFPB Disclosure Requirements Dodd-Frank Mortgages

Special Alert: Banking Agencies Adopt Final Rule Requiring Appraisals For Higher-Priced Mortgage Loans

On January 18, the Federal Reserve Board, Consumer Financial Protection Bureau (CFPB), Federal Deposit Insurance Corporation, Federal Housing Finance Agency, National Credit Union Administration, and Office of the Comptroller...more

1/31/2013 - CFPB Dodd-Frank ECOA Higher-Priced Mortgage Loans Mortgages

InfoBytes Special Alert: Detailed Analysis Of CFPB's High-Cost Mortgage Rule - January 25, 2013

On January 10, 2013, the Consumer Financial Protection Bureau (the “Bureau”) issued a final rule (the “Rule”) that amends Regulation Z (Truth in Lending) to implement changes to the Home Ownership and Equity Protection Act...more

1/25/2013 - CFPB Disclosure Requirements Dodd-Frank Higher-Priced Mortgage Loans HOEPA Loans Mortgages Regulation Z TILA

Infobytes Special Alert: Detailed Analysis Of CFPB's Final Ability-To-Repay/Qualified Mortgage Rule

After considering a proposed rule and comments for more than a year and a half, the Consumer Financial Protection Bureau (the “Bureau”) has issued its highly anticipated final “Ability-to-Repay” rule (the “Rule”) governing...more

1/24/2013 - Ability-to-Repay CFPB Foreclosure Higher-Priced Mortgage Loans Mortgages Qualified Mortgage Rule Regulation Z Safe Harbors TILA Underwriting

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