Marc Patterson

Marc Patterson

Ballard Spahr LLP

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NMLS Releases MLO and Lender Numbers

The NMLS recently released its NMLS Mortgage Industry Report 2014 Q3 Update. According to the report, there were 343,800 state-licensed mortgage loan originators (MLOs) during the 2014 third quarter, a 10 percent increase...more

12/19/2014 - Mortgage Lenders Mortgage Loan Originators Mortgage Servicers NMLS Quarterly Report

Massachusetts Issues FAQs and Sample Form for Flood Insurance Disclosure

The Massachusetts Division of Banks recently released Frequently Asked Questions (FAQs) to provide guidance on complying with Chapter 177 of the Acts of 2014, “An Act Further Regulating Flood Insurance” (Chapter 177). Chapter...more

12/5/2014 - Disclosure Requirements Flood Insurance Mortgage Lenders

Montana Announces License Renewal Fees

The Montana Department of Administration (Department) has adopted changes to mortgage license renewal fees. According to the amendment, the Department realized that, due to an oversight, renewal fees for the 125 mortgage...more

11/26/2014 - License Renewals Mortgage Servicers Renewal Fees

CFPB gives guidance and answers FAQ on the new Closing Disclosure

On November 18, 2014, the CFPB staff and Federal Reserve Board co-hosted a webinar that addressed questions about the Final TILA-RESPA Integrated Disclosure Rule that will be effective for applications received by creditors...more

11/21/2014 - CFPB Federal Reserve Fee Disclosure Final Rules Lenders Mortgage Brokers Mortgages RESPA TILA

NMLS Announces ‘Your License is Your Business’ Renewal Campaign

The NMLS is launching its “Your License is Your Business” renewal campaign to encourage non-depository entities and mortgage loan originators (MLOs) licensed through the NMLS to submit their annual renewal requests early....more

11/7/2014 - Licenses MLO Licenses Mortgage Loan Originators Mortgages NMLS

Federal agencies adopt Dodd-Frank risk retention rule

On October 22, 2014, six federal agencies adopted the final Credit Risk Retention Rule under Section 941 of the Dodd-Frank Act. The final rule will require sponsors of securitizations to retain an economic interest in the...more

10/27/2014 - ABS Asset-Backed Securities Dodd-Frank FDIC FHFA Final Rules HUD OCC Qualified Mortgage Rule SEC Securitization

Federal Agencies Propose New Flood Insurance Rules

The Federal Deposit Insurance Corporation (FDIC) recently approved proposed regulations related to the mandatory escrow and detached structure requirements for loans secured by property located in special flood hazard areas....more

10/27/2014 - FDIC Flood Disaster Protection Act Flood Insurance HFIAA Insurers

New York Issues Renewal of Exempt Loan Servicer Registration Requirements

The New York Department of Financial Services (DFS) has announced new procedures that require exempt mortgage loan servicers to renew their registration each year. All renewals for exempt mortgage servicers must be submitted...more

10/24/2014 - License Renewals Loan Servicer Mortgage Servicers Registration

CFPB Proposes Changes to TILA-RESPA Integrated Disclosures Rule

The CFPB has issued two proposed changes to the TILA-RESPA Integrated Disclosures Rule (Final Rule) that will be effective for applications received on or after August 1, 2015: (1) an adjustment to the timing requirement for...more

10/15/2014 - CFPB Compliance Disclosure Requirements Mortgages RESPA TILA

CFPB Updates Mortgage Rules Readiness Guide to Cover TILA-RESPA Integrated Mortgage Disclosure Rule

The CFPB has released Version 3.0 of its “2014 CFPB Dodd-Frank Mortgage Rules Readiness Guide.” The Guide, originally issued in July 2013, now contains changes to the final rules issued through August 1, 2014. The updated...more

10/10/2014 - CFPB Dodd-Frank Final Rules Mortgages RESPA TILA

CFPB Provides Guidance on the New Loan Estimate

On October 1, 2014, the CFPB staff and Federal Reserve Board co-hosted a webinar that addressed questions about the Final TILA-RESPA Integrated Disclosure Rule that will be effective for applications received by creditors or...more

10/8/2014 - CFPB Closing Documents Creditors Disclosure Requirements Federal Reserve Mortgage Brokers Mortgages RESPA TILA Webinar

Vermont Updates Mortgage Broker Rules

The Vermont Department of Financial Regulation has adopted regulations that update the rules for the licensing and regulation of mortgage brokers. The regulation sets forth standards on...more

9/30/2014 - Lenders Licensing Rules Mortgage Brokers Mortgage Loan Originators New Regulations Secured Lenders

Industry trade groups provide recommendations to CFPB on TILA-RESPA implementation

Sixteen industry trade groups, including the American Bankers Association, the Mortgage Bankers Association, and Financial Services Roundtable, have sent a letter to Director Cordray in which they requested that the CFPB...more

9/25/2014 - American Bankers Association Banks CFPB Mortgages RESPA Richard Cordray TILA

VA Announces Upcoming Changes to ARM Disclosure Regulations

On September 5, 2014, the Department of Veterans Affairs (VA) announced in Circular 26-14-25 that it intends to clarify its interest-rate adjustment, disclosure, and notice requirements for ARM and hybrid ARM mortgage loans...more

9/18/2014 - Adjustable-Rate Mortgage CFPB Department of Veterans Affairs Disclosure Requirements Government-Guaranteed Loans Interest Rates Mortgage Servicing Rules Mortgages TILA

HUD Issues Final Rule Eliminating ‘Post Payment’ Interest Charges, Preventing FHA Loans from Being Prohibited Next Year

On August 26, 2014, the U.S. Department of Housing and Urban Development (HUD) issued a final rule to allow FHA-approved lenders to charge an FHA loan borrower interest only through the date the loan is prepaid. The final...more

9/17/2014 - Ability-to-Repay CFPB FHA Final Rules HUD Interest Payments Prepayment Penalties

HUD Issues Final Rule Regarding ARM Disclosures

On August 26, 2014, the U.S. Department of Housing and Urban Development (HUD) issued a final rule to align HUD rules governing FHA-insured adjustable mortgage rates (ARMs) with the recent CFPB rules regarding ARM interest...more

9/16/2014 - Adjustable-Rate Mortgage FHA HUD Mortgages

CFPB issues updated guides on the TILA-RESPA Integrated Disclosure Rule

The CFPB has released its updated Small Entity Compliance Guide for the TILA-RESPA Integrated Disclosure Rule and Guide to the Loan Estimate and Closing Disclosure. These resources replace the editions that were published in...more

9/10/2014 - CFPB Disclosure Requirements Federal Reserve RESPA TILA

California Creates Exemption from Finance Lenders Law for Certain Nonprofits

The state of California amended its Finance Lenders Law in an effort to help individuals obtain access to affordable, credit-building small dollar loans. The new law makes exempt from Finance Lenders Law a nonprofit...more

9/4/2014 - Amended Legislation Banking Sector Finance Lenders Lenders Loans Non-Profits Nonbank Firms

CFPB Answers FAQ on the TILA-RESPA Integrated Disclosures Rule

On August 26, 2014, the CFPB staff and Federal Reserve Board co-hosted a webinar and addressed questions about the final TILA-RESPA Integrated Disclosures Rule that will be effective for applications received by creditors or...more

8/29/2014 - CFPB Creditors Disclosure Requirements Final Rules Mortgage Brokers RESPA TILA

California Amends Education Requirements for Mortgage Loan Originators

California recently amended its pre-licensing and continuing education requirements for mortgage loan originators (MLOs) licensed under the California Finance Lenders Law and the California Residential Lending Act. The...more

8/18/2014 - Licensing Rules Mortgage Loan Originators Mortgages NMLS

D.C. Passes NMLS Conformity Temporary Act of 2014

Recently, Washington, D.C., Mayor Vincent Gray signed the NMLS Conformity Temporary Act of 2014. The Act authorizes the Department of Insurance, Securities and Banking (DISB) the necessary statutory authority to use the NMLS...more

8/18/2014 - Banks Financial Regulatory Reform Mortgages NMLS

CFPB announces settlement with mortgage lender and its owner charged with “bait-and-switch” scheme

On August 12, the CFPB announced that it has issued a Consent Order under which Atlanta-based Amerisave Mortgage Corporation, its affiliate appraisal management company, Nova Appraisal Management Company, and a principal and...more

8/14/2014 - CFPB Mortgages Qualified Mortgage Rule RESPA

Several New States Adopt the National SAFE MLO Test with Uniform State Component

New York, Ohio, Oklahoma, and Connecticut are the latest states to announce that they will be adopting the National SAFE Mortgage Loan Originator (MLO) Test with Uniform State Content. The New York Department of Financial...more

8/7/2014 - Banking Sector Banks Financial Institutions Licenses Licensing Rules Mortgage Loan Originators Mortgages

The State Regulatory Registry Proposes Pre-Licensure Education Expiration Policy

The State Regulatory Registry LLC, through NMLS, recently published a proposal to create a uniform time frame for the expiration of pre-licensure education (PE) for state licensed Mortgage Loan Originators (MLO). The comment...more

8/4/2014 - Mortgage Loan Originators Mortgages NMLS SAFE Act

CFPB extends comment period on proposal to publicly disclose consumer complaint narratives

The CFPB is extending the comment period on its proposed policy statement that would expand the complaint data that it publicly discloses in its Consumer Complaint Database to include “unstructured” complaint narratives. In a...more

7/31/2014 - CFPB Consumer Complaint System Disclosure Public Disclosure

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