Richard J. Andreano, Jr.

Richard J. Andreano, Jr.

Ballard Spahr LLP

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CFPB posts 2015 final lists of rural and rural or underserved counties

The CFPB has posted its 2015 final lists of Rural and Rural or Underserved Counties on its website. The CFPB has previously posted lists of such counties for calendar years 2011-2014....more

10/28/2014 - CFPB Rural Development

ABA renews request for CFPB clarification on rolling mortgage delinquencies

This past July, the American Bankers Association sent a letter to the CFPB requesting several clarifications to the mortgage servicing rules. One of such clarifications concerned application of the “120-day rule,” meaning the...more

10/28/2014 - American Bankers Association Banks CFPB Delinquent Borrowers Mortgage Servicing Rules Mortgages

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

CFPB updated mortgage servicing transfer guidance published in Federal Register

In yesterday’s Federal Register, the CFPB published the compliance bulletin and policy guidance (Bulletin 2014-01) regarding mortgage servicing transfers that it previously issued on August 19, 2014 (New Guidance). The New...more

10/24/2014 - CFPB Mortgage Loan Servicing Standards Mortgage Servicers Mortgage Servicing Rules

CFPB finalizes amendments to mortgage rules

The CFPB has issued a final rule amending certain provisions of the 2013 Title XIV final mortgage rules. While in its press release the CFPB describes the amendments as “minor adjustments to its mortgage rules,” the final...more

10/24/2014 - CFPB Mortgage Servicing Rules Mortgages RESPA TILA Title XIV

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

CFPB settles RESPA charges for marketing services agreements allegedly tied to referrals

The CFPB has announced that it has entered into a consent order with a Michigan title insurance agency to settle charges that the agency violated the Real Estate Settlement Procedures Act (RESPA) by paying fees to various...more

10/2/2014 - CFPB Consent Order Marketing Referral Fees RESPA Title Companies

NY Attorney General Files Redlining Lawsuit Alleging Mortgage Discrimination

The New York Attorney General filed a complaint this week in a New York federal court against a national bank headquartered in the state and its holding company alleging that the defendants violated the federal Fair Housing...more

9/5/2014 - Attorney Generals Bank Holding Company Banks Discrimination Disparate Impact DOJ FHA HMDA Mortgages Redlining

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

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

ABA seeks CFPB clarification of mortgage servicing rules

The American Bankers Association has sent a letter to the CFPB requesting several clarifications to the mortgage servicing rules. The ABA asks the CFPB to make the clarifications part of “regulatory guidance (or regulatory...more

8/4/2014 - American Bankers Association Banking Sector Banks CFPB Examiners Mortgage Servicers Mortgage Servicing Rules Regulatory Standards

Fourth Circuit Limits Liability under Maryland Finder’s Fee Act

In two recent opinions, the U.S. Court of Appeals for the Fourth Circuit substantially limited the potential scope of liability under the Maryland Finder’s Fee Act. Applying the plain language of the statute, the Fourth...more

7/30/2014 - Brokers Finder's Fees Mortgages

CFPB Provides Guidance on Ability-To-Repay Rule Application to Assumptions of Residential Mortgage Loans

The CFPB recently provided guidance on the application of the Regulation Z ability-to-repay rule (Section 1026.43) to assumptions of residential mortgage loans for purposes of clarifying the application of the rule in cases...more

7/17/2014 - Ability-to-Repay Beneficiaries CFPB Mortgages Popular Regulation Z TILA

CFPB issues policy guidance on mini-correspondent structure for mortgage lenders

On July 11, 2014, the CFPB issued supervisory and enforcement guidance entitled “Policy Guidance on Supervisory and Enforcement Considerations Relevant to Mortgage Brokers Transitioning to Mini-Correspondent Lenders.” The...more

7/15/2014 - CFPB Lenders Mortgages RESPA TILA

CFPB Provides Guidance on Ability to Repay Rule Application to Assumptions of Residential Mortgage Loans

On July 8, 2014 the CFPB provided guidance on the application of the Regulation Z ability to repay rule (section 1026.43) to assumptions of residential mortgage loans for purposes of clarifying the application of the rule in...more

7/9/2014 - Beneficiaries CFPB Mortgages Regulation Z

House passes bill to modify TILA “points and fees” definition

H.R. 3211, which amends the Truth in Lending Act’s definition of “points and fees,” was passed by a voice vote in the House of Representatives on June 9, 2014. The “points and fees” definition is used to determine...more

6/13/2014 - Mortgages RESPA TILA

CFPB issues small entity compliance guide for RESPA/TILA integrated disclosure rule

The CFPB recently issued an 89-page small entity compliance guide for the TILA-RESPA Integrated Disclosure Rule (the “Guide”). As we reported previously, the CFPB issued the final rule in November 2013 to integrate the...more

4/3/2014 - CFPB Mortgage Loan Servicing Standards Mortgages RESPA TILA

Flood Insurance Reform Bill with Escrow Amendments Awaits President’s Signature

The U.S. House of Representatives and Senate recently passed, and the President is expected to sign into law, amendments to the Biggert-Waters Flood Insurance Reform Act of 2012 (the Act). The legislation seeks to address...more

3/19/2014 - Biggert-Waters Flood Insurance Reform Act Flood Insurance Insurers Loans Mortgage Escrow Account Mortgages Premiums

HUD Issues Proposal to Avoid FHA Loans From Being Prohibited Starting Next Year

On March 13, 2014, HUD published a proposal to eliminate the requirement that an FHA loan borrower be required to pay interest after the loan is prepaid. The move is needed because the requirement would effectively cause FHA...more

3/17/2014 - CFPB FHA HUD Mortgages

CFPB settles self-reported RESPA violations

The CFPB announced today that it has issued a Consent Order under which a Connecticut mortgage lender that self-reported potential RESPA Section 8 violations agreed to pay an $83,000 civil money penalty for such...more

2/24/2014

CFPB supervisory report highlights exam report changes, non-public supervisory actions and mortgage servicing deficiencies

Last month, the CFPB began using new templates for its examination reports and supervisory letters (collectively, “reports’). The template changes were announced in the CFPB’s Winter 2013 Supervisory Report, which highlights...more

2/3/2014 - CFPB Compliance Enforcement Actions Investigations Mortgage Loan Servicing Standards Mortgages

CFPB settles RESPA referral fee charges against mortgage lender based on rent payments

The CFPB has announced that it has issued a Consent Order to settle charges that a mortgage lender and its principal violated RESPA Section 8 by paying illegal kickbacks to a bank in exchange for mortgage loan referrals....more

1/17/2014 - Banking Sector Borrowers CFPB Contract Drafting Disgorgement Dodd-Frank HUD Kickbacks Lenders Real Estate Market RESPA

CFPB issues revised mortgage servicing and origination exam procedures

The CFPB has revised its examination procedures for mortgage servicing and mortgage origination. The revisions are intended to update the CFPB’s existing examination procedures to reflect the new mortgage rules which became...more

1/14/2014 - CFPB Mortgage Loan Originators Mortgage Loan Servicing Standards Mortgages

CFPB’s fact vs. fiction guide: useful information for consumers or defense planning?

With the January 10 effective date imminent, the CFPB has issued what it labels a “fact vs. fiction guide” on its ability-to-repay/qualified mortgage rule. According to the CFPB, the guide is intended “to help dispel some of...more

1/8/2014 - Borrowers CFPB Lenders Mortgages Qualified Mortgage Rule Real Estate Market

CFPB to hold mortgage servicing rule training event

The CFPB has announced that on January 10, 2014, the date on which most of its new mortgage rules take effect, it will host an event entitled “Protecting homeowners: New tools for empowering consumers and advocates.” The...more

1/7/2014 - CFPB Mortgage Loan Servicing Standards Mortgages

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