John Kromer

John Kromer

BuckleySandler LLP

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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)

The CFPB’s Mortgage Originations Agenda in 2016

Now more than ever, financial services firms need to proactively focus on issues of concern identified by the CFPB and ensure that they are engaged in industry best practices that are clearly identified and carefully...more

12/16/2015 - Best Practices CFPB Financial Services Industry Mortgage Loan Originators TILA-RESPA Integrated Disclosure Rule (TRID) UDAAP

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: 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 Finalizes Rule to Oversee Nonbank Auto Lenders

On June 10, the CFPB issued its final rule to oversee “larger participant” nonbank auto finance companies. Although the CFPB received significant feedback during the comment period, the final rule is nearly identical to that...more

6/12/2015 - Automotive Loans CFPB Debt Collection ECOA Federal Register Financial Institutions Financial Markets Lenders Nonbank Firms Securitization

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: CFPB Releases Outline Of Proposed Rule For Payday, Vehicle Title, And Similar Loans

On March 26, the CFPB announced that it is considering proposing a rule to “end payday debt traps” and released several related documents, including a fact sheet and an outline of the proposal that will be presented to a...more

3/30/2015 - CFPB Consumer Lenders Payday Loans Proposed Regulation SBREFA Title Loans

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

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

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)

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 Truth in Lending Act (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

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 Fair Housing Act (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 Truth in Lending Act (TILA)

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