Reid Herlihy

Reid Herlihy

Ballard Spahr LLP

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Latest Publications


CFPB Proposes Additional Servicing Rule Amendments

The CFPB issued a proposed rulemaking last week to amend various provisions of the mortgage servicing rules under Regulation X and Regulation Z. Comments are due 90 days from the date of publication in the Federal Register....more


Leading industry trade groups comment on HMDA/Reg. C proposal

Six leading industry trade groups have submitted a letter commenting on the CFPB’s proposed rule amending Regulation C to expand Home Mortgage Disclosure Act data reporting requirements. The trade groups consist of the...more

11/4/2014 - CFPB HMDA Proposed Amendments Regulation C Reporting Requirements Trade Associations

CFPB Issues First Enforcement Action for Servicing Rules Violations

The Consumer Financial Protection Bureau recently announced a consent order with Flagstar Bank, F.S.B., alleging unfair acts and practices under the Consumer Financial Protection Act (CFPA) and violations of the CFPB's...more

10/3/2014 - Banks CFPB Civil Monetary Penalty Consent Order Enforcement Actions Loan Modifications Mortgage Loan Servicing Standards UDAAP Unfair or Deceptive Trade Practices

New York Proposes Virtual Currency Licensing and Regulatory Framework

The New York Department of Financial Services (DFS) recently proposed a regulatory framework for virtual currency firms. In doing so, New York is the first state to propose a specially tailored regulatory framework for...more

8/15/2014 - Bitcoins Financial Regulatory Reform Virtual Currency

Senator Hagan Introduces the Servicemember Higher Education Protection Act

New legislation, titled the Servicemember Higher Education Protection Act (the “Bill”), was introduced recently by Senator Kay Hagan (D-NC). The Bill includes several provisions that expand protections under the...more

6/17/2014 - Military Service Members SCRA Student Loans Veterans

Ginnie Mae Issues Clarification on Electronic Signatures and Documents

Ginnie Mae recently issued All Participant Memorandum 2014-01, which clarifies its position on electronic signatures and documents. In response to the Federal Housing Administration's recent announcement (Mortgagee Letter...more

3/20/2014 - Digital Signature Standards Ginnie Mae Mortgages Signatures

FHA Permits Electronic Signatures

FHA recently issued Mortgagee Letter 2014-03, which states that effective immediately, FHA will accept electronic signatures on a voluntary basis for the following documents...more

2/17/2014 - E-SIGN FHA Signatures

CFPB explores HMDA changes

The CFPB announced it will begin the rulemaking process for changes to the reporting requirements under the Home Mortgage Disclosure Act (HMDA). As an initial step, the CFPB will convene a Small Business Review Panel to seek...more

2/11/2014 - CFPB Dodd-Frank Financial Regulatory Reform HMDA Lenders Mortgages Reporting Requirements

Washington Amends Its Consumer Loan Act Licensing Regulations

The Washington Department of Financial Institutions (Department) recently issued a new rule clarifying the licensing requirements for individual managers of Consumer Loan Company Licensees. The new rule became effective on...more

2/3/2014 - MLO Licenses Mortgage Loan Originators Mortgages

FHA Extends Recertification Deadline for Title I and Title II Mortgagees with Fiscal Year End of December 31, 2013

The Federal Housing Administration (FHA) recently issued Mortgagee Letter 2013-42, which extends the annual recertification filing deadline for Title I and Title II lenders and mortgagees that have a fiscal year end of...more

12/9/2013 - FHA Lenders Mortgages Title II

FHA Issues Mortgagee Letter Clarifying Lender Self-Reporting Requirements

Possibly in response to the CFPB's recent emphasis on self-reporting, FHA issued Mortgagee Letter 2013-41 last week, which clarifies the self-reporting requirements for Single Family FHA-approved lenders. Ballard Spahr has...more

11/25/2013 - CFPB Compliance FHA Mortgages Reporting Requirements Self-Reporting

CFPB issues another update to the Small Entity Compliance Guide for ATR/QM

The CPFB recently issued another update to the Small Entity Compliance Guide for the Ability-to-Repay and Qualified Mortgage Rule, to reflect changes from the October 2013 Final Rule. The updated guide clarifies several...more

11/5/2013 - Ability-to-Repay CFPB Qualified Mortgage Rule Small Entity Compliance Guide

HUD issues proposed rule on qualified mortgage definition for HUD insured and guaranteed single family mortgages

As anticipated, HUD recently issued its proposed rule defining a qualified mortgage (QM) for HUD insured and guaranteed single family mortgages. Under the proposed rule, published in the Federal Register on Monday, Title II...more

10/4/2013 - CFPB HUD Interest Rates Mortgages Qualified Mortgage Rule Safe Harbors

CFPB Finalizes Amendments to Mortgage Rules

The Consumer Financial Protection Bureau (CFPB) has finalized several amendments and clarifications to the mortgage rules that had been proposed on June 24, 2013. The amendments include revisions to the CFPB's mortgage...more

9/19/2013 - Ability-to-Repay CFPB Loan Originator Compensation Rule Mortgage Loan Originators Mortgages

D.C. Bar hosts presentation on CFPB enforcement priorities

The District of Columbia Bar recently hosted a presentation on CFPB enforcement priorities. The sole speaker was Mr. Hunter Wiggins, Deputy Enforcement Director of Policy and Strategy of the CFPB’s Supervision, Enforcement &...more

9/3/2013 - CFPB Enforcement Strategic Enforcement Plan

CFPB updates Small Entity Compliance Guide for ATR/QM Rule

On August 14th, the CFPB released an update to the Small Entity Compliance Guide for the Ability-to-Repay and Qualified Mortgage Rule, incorporating the changes made in the June 2013 Concurrent Final Rule and July 2013 Final...more

8/16/2013 - Ability-to-Repay CFPB Compliance Final Rules Qualified Mortgage Rule Small Entity Compliance Guide

Federal financial regulatory agencies propose appraisal requirement exemptions for certain higher-priced mortgage loans

The CFPB, Federal Reserve Board, FDIC, FHFA, NCUA, and OCC published in the Federal Register on August 8, 2013 proposed rules creating several exemptions to the appraisal requirements for higher-priced mortgage loans....more

8/9/2013 - Appraisal CFPB Exemptions FDIC Federal Reserve FHFA Higher-Priced Mortgage Loans Mortgages NCUA OCC

CFPB Releases Exam Procedures for New Mortgage Rules

This week, the CFPB published an update to its examination procedures to account for the new mortgage regulations going into effect in January 2014. The update includes Interim TILA Examination Procedures and Interim ECOA...more

6/10/2013 - Arbitration CFPB ECOA Escrow Accounts Mortgage Loan Originators Mortgages TILA

Notes from CFPB Education Conference for State Attorneys General

The George Mason University School of Law, Law & Economics Center recently hosted a conference titled “Understanding the Consumer Financial Protection Bureau,” through GMU’s Attorneys General Education Program. Founded in...more

5/13/2013 - Attorney Generals CFPB Loan Originator Compensation Rule Loans Mortgages Payday Loans Qualified Mortgage Rule

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