The CFPB soon plans to issue a final rule that would require certain supervised nonbank entities to register with it and provide information about their use of certain terms and conditions in standard-form contracts for...more
The CFPB has released its Summer, 2024 Supervisory Highlights, covering issues ranging from student loan servicing to financial institution supervision of medical providers offering payment products. The report covers the...more
Providers of consumer financial services that rely on federal preemption to charge customers uniform interest rates and fees on a nationwide basis are currently facing a series of legislative and litigation challenges. In...more
12/21/2023
/ Banking Sector ,
Certiorari ,
Chevron Deference ,
Dodd-Frank ,
FDIC ,
Financial Services Industry ,
Interest Rates ,
National Bank Act ,
OCC ,
Preemption ,
SCOTUS ,
State Banks ,
True Lender
Continuing its (and the White House’s) “junk fees” rhetoric, the CFPB has released a new issue of Supervisory Highlights that carries the title “Junk Fees Special Edition.” The report discusses the Bureau’s examinations...more
In the latest demonstration that there’s a “new CFPB” as well as other new regulatory sheriffs in town, the CFPB, the federal banking agencies (OCC, FDIC, Federal Reserve Board, and NCUA), and state financial regulators...more
The Pennsylvania Department of Banking and Securities recently published Frequently Asked Questions to clarify its new mortgage servicer licensing requirements. ...more
The Ohio Residential Mortgage Lending Act (ORMLA) becomes effective on March 23, 2018. Passed in December 2017 (H.B. 199), the ORMLA consolidates the regulation and licensing of first- and subordinate-lien mortgage loans into...more
The CFPB recently issued two updates for its Mortgage Servicing Rule amendments to Regulations X and Z. Issued on August 4, 2016, the Mortgage Servicing Final Rule amended various aspects of the existing Mortgage Servicing...more
The U.S. Treasury Department recently issued a report titled “A Financial System That Creates Economic Opportunities-Banks and Credit Unions.” In addition to recommended changes for the CFPB, the report devotes substantial...more
6/30/2017
/ Banking Sector ,
Basel III ,
Fannie Mae ,
Financial Services Industry ,
Freddie Mac ,
HMDA ,
Housing Market ,
Mortgage Lenders ,
Mortgage Servicing Rules ,
Mortgages ,
Qualified Mortgage Rule ,
Regulatory Oversight ,
TILA-RESPA Integrated Disclosure Rule (TRID) ,
U.S. Treasury
The CFPB recently announced that it has entered into a consent order with Fay Servicing, LLC (“Fay”) to settle alleged mortgage servicing violations. A copy of the consent order can be found here. As is typical for CFPB...more
The Maryland Commissioner of Financial Regulation recently issued a revised proposed regulation impacting servicing transfers. The Commissioner previously issued proposed regulations on this topic in January 2015. This...more
The CFPB Mortgage Servicing Rule Amendments were published in the Federal Register yesterday, starting the clock for the effective date of the amended provisions. Most of the provisions are effective on October 19, 2017. ...more
10/21/2016
/ Banking Sector ,
Borrowers ,
Consumer Bankruptcy ,
Consumer Financial Protection Bureau (CFPB) ,
FDCPA ,
Federal Register ,
Financial Institutions ,
Financial Services Industry ,
Interpretive Rule ,
Mortgage Servicers ,
Mortgage Servicing Rules ,
Mortgages
The Consumer Financial Protection Bureau (CFPB) issued its final rule amending the mortgage servicing rules under Regulations X and Z. The proposal for these amendments was issued in November 2014. The amended provisions...more
8/22/2016
/ Banking Sector ,
Consumer Financial Protection Bureau (CFPB) ,
FDCPA ,
Mortgage Servicers ,
Mortgage Servicing Rules ,
Mortgages ,
Popular ,
Real Estate Market ,
Regulation X ,
Regulation Z ,
TILA-RESPA Integrated Disclosure Rule (TRID)
In an unmistakable warning shot to mortgage servicers, the CFPB recently issued a “Mortgage Servicing Special Edition” of its Supervisory Highlights. The CFPB also updated portions of its Mortgage Servicing Examination...more
7/8/2016
/ Banking Sector ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
HAMP ,
Industry Examinations ,
Loan Modifications ,
Loss Mitigation ,
Mortgage Servicers ,
Mortgages ,
Regulation X ,
Supervisory Highlights ,
Technology
The CFPB recently issued Compliance Bulletin 2015-03, addressing the cancellation and termination requirements for private mortgage insurance (PMI) under the Homeowners Protection Act of 1998 (HPA). We note that this Bulletin...more
8/10/2015
/ Banking Sector ,
Banks ,
Best Practices ,
Cancellation Rights ,
Compliance ,
Consumer Financial Protection Bureau (CFPB) ,
Financial Institutions ,
Homeowners Protection Act ,
Insurance Industry ,
Mortgage Insurance ,
Mortgages ,
Real Estate Market ,
Residential Real Estate Market ,
Termination