Jennifer M. Keas

Jennifer M. Keas

Foley & Lardner LLP

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Latest Publications


A Response to the CFPB’S Recent Compliance Bulletin on MSAs

On October 8, 2015, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a Compliance Bulletin on RESPA Compliance and Marketing Services Agreements (“MSAs”)(“Compliance Bulletin”).  The Compliance Bulletin’s...more

10/20/2015 - Affiliated-Business Arrangements CFPB Disclosure Requirements Enforcement Actions Kickbacks Marketing Marketing Services Agreements Quid Pro Quo Referral Fees RESPA Safe Harbors

Are Aggregators of Government-Created Data the Next Target for Large Class Action Lawsuits?

There is little doubt that large class action lawsuits are a content aggregator’s worst nightmare. This especially holds true for those who transact significant amounts of data which may include government-created public...more

7/21/2015 - Amicus Briefs Class Action Content Aggregators FCRA Personal Data Public Records SCOTUS Spokeo v Robins Standing

CFPB Director Cordray Issues First-Ever Agency Appellate Decision in RESPA Case

The Director of the Federal Consumer Financial Protection Bureau (CFPB), Richard Cordray, issued a decision yesterday in the first appeal of a Bureau administrative enforcement action. Cordray’s decision upholds in part,...more

6/5/2015 - Administrative Appeals ALJ CFPB Disgorgement Dodd-Frank Enforcement Actions HUD Injunctive Relief Kickbacks Mortgage Insurance Referral Fees Reinsurance RESPA Richard Cordray SEC Statute of Limitations Title X

Recent Settlements of Joint UDAAP Enforcement Between State and Federal Regulators

The Dodd-Frank Act (“Dodd-Frank”) granted to state attorneys general and state regulators much of the Consumer Financial Protection Bureau’s (“CFPB”) UDAAP authority. In particular, Dodd-Frank gives state attorneys authority...more

3/9/2015 - Attorney Generals CFPA CFPB Dodd-Frank Financial Institutions Nonbank Firms NYDFS State Action Doctrine UDAAP

CFPB to Shine Spotlight on Mini-Correspondent Mortgage Lending?

On July 9, 2014, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) issued Policy Guidance on the issue of Mortgage Brokers Transitioning to Mini-Correspondent Lenders (“Policy Guidance”), which highlights risks...more

7/21/2014 - CFPB Lenders Mortgage Brokers Mortgages

Sixth Circuit in Carter Refuses to Defer to HUD’s RESPA Guidelines

In a decision two years in the making, on Wednesday, November 27, 2013, the Sixth Circuit Court of Appeals brought some clarity to the use of affiliated business arrangements (“ABAs”) under Real Estate Settlement Procedures...more

12/11/2013 - Affiliated-Business Arrangements Compliance HUD RESPA Rule of Lenity

CFPB Continues to Finalize Elements of “Points and Fees” Test as Implementation Date Draws Closer

The CFPB’s final ability-to-repay rule (Rule), issued January 10, 2013, implements Dodd-Frank mortgage reforms requiring creditors to make good faith determination that a consumer has reasonable ability to repay his or her...more

7/19/2013 - Ability-to-Repay CFPB Compliance Creditors Dodd-Frank Good Faith New Regulations

Negotiating the Enforcement Maze: A CFPB Civil Investigative Demand

The Consumer Financial Protection Bureau (CFPB or Bureau), through its Office of Enforcement, may conduct inquiries of institutions or persons to investigate compliance with the federal consumer financial laws for which it is...more

4/5/2013 - CFPB CID Compliance Document Requests Electronically Stored Information Meet and Confer

CFPB Proposes Amendments to New Final Ability-to-Repay Rule, Solicits Comment on Calculating Loan Originator Compensation

On January 10, 2013, the CFPB issued its final ability-to-repay rule (Rule), which implements Dodd-Frank mortgage reforms requiring creditors to make a reasonable and good faith determination that a consumer will have a...more

1/28/2013 - Ability-to-Repay CFPB Dodd-Frank Mortgage Loan Originators Mortgages Qualified Mortgage Rule Truth in Lending Act (TILA)

Final Rule Issued on Ability-to-Repay/Qualified Mortgages

The Consumer Financial Protection Bureau (CFPB) issued its final ability to repay rule (Rule) on January 10, 2013. The Rule implements ability-to-repay provisions of the Dodd-Frank Act, which imposed strict underwriting...more

1/15/2013 - Ability-to-Repay Borrowers Dodd-Frank Lenders Loans Mortgages Penalties Qualified Mortgage Rule Rebuttable Presumptions Safe Harbors Truth in Lending Act (TILA) Underwriting

Developments in Law, Factual Discovery Lead Federal Judge to Decertify Class Action

In Campbell v. First American, a federal judge in Maine has issued a ruling decertifying a class action involving claims that First American Title Insurance Co. overcharged refinance customers for their title insurance....more

12/24/2012 - Class Action Class Certification Commonality Decertify Title Insurance

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