Jeffrey Naimon

Jeffrey Naimon

BuckleySandler LLP

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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: 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

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: Detailed Analysis Of CFPB's Final Escrow Rule

On January 10, 2013, the Consumer Financial Protection Bureau issued its final rule on escrow account requirements for first-lien higher-priced mortgage loans. The rule amends existing escrow requirements and exemptions for...more

2/15/2013 - Ability-to-Repay Appraisal CFPB Condominiums Disclosure Requirements Dodd-Frank Escrow Holders First-Lien Higher-Priced Mortgage Loans HOEPA Loans Mortgage Escrow Account Prepayment Penalties PUDs Regulation Z RESPA TILA

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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