Richard J. Andreano, Jr.

Richard J. Andreano, Jr.

Ballard Spahr LLP

Contact  |  View Bio  |  RSS

Latest Publications

Share:

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

CFPB adds list of rural and underserved counties for 2011

The CFPB has posted on its website a list of rural and underserved counties for calendar year 2011. The CFPB had already posted lists of such counties for calendar years 2012 and 2013....more

1/3/2014 - CFPB Rural Development

CFPB seeking information on mortgage closing process

According to the notice, because the CFPB wants “to encourage the development of a more streamlined, efficient, and educational closing process as the mortgage industry increases its usage of technology, electronic...more

1/3/2014 - CFPB Closing Documents Mortgage Servicers Real Estate Market

Will the CFPB’s mortgage education campaign encourage consumers to sue?

Last week, the CFPB announced that it has launched “a campaign to educate the public about the new protections provided by the Bureau’s mortgage rules.” Consumers could, however, misinterpret the CFPB’s message as an...more

12/24/2013 - CFPB Financial Education Initiatives Foreclosure Loss Mitigation Mortgages

CFPB updates Mortgage Rules Readiness Guide

The CFPB has issued Version 2.0 of its “2013 CFPB Dodd-Frank Mortgage Rules Readiness Guide.” The Guide, originally issued in July 2013, is intended “to help financial institutions come into and maintain compliance with” the...more

12/17/2013 - CFPB Dodd-Frank Mortgage Rules

Federal financial regulatory agencies finalize appraisal requirement exemptions

The CFPB, Fed, FDIC, FHFA, NCUA, and OCC have finalized a supplemental rule creating several exemptions to the appraisal requirements for higher-priced mortgage loans (HPML). Those requirements are contained in the final rule...more

12/17/2013 - Appraisal Higher-Priced Mortgage Loans Mortgage Loan Originators Mortgages

CFPB Releases Final RESPA-TILA Integrated Disclosures Rule

On November 20, the Consumer Financial Protection Bureau released the nearly 1,900-page final RESPA-TILA Integrated Disclosures Rule. The rule will be effective for applications received on or after August 1, 2015. The...more

11/26/2013 - CFPB Mortgages RESPA TILA

CFPB issues final consolidated mortgage disclosure rule

Today, the CFPB issued its long-awaited final rule consolidating the application and closing disclosures required by the Real Estate Settlement Procedures Act and Truth in Lending Act for mortgage loan transactions....more

11/20/2013 - CFPB Mortgages RESPA TILA

DOJ Settles Fair Lending Cases against Mortgage Lenders

The U.S. Department of Justice (DOJ) recently settled fair lending lawsuits against two mortgage lenders. Both actions involved DOJ attempts to use disparate impact evidence to establish that a lender engaged in a “pattern or...more

11/12/2013 - Discrimination DOJ Fair Lending Mortgages National Origin Discrimination Racial Discrimination

CFPB settles lawsuit challenging loan officer bonuses

For mortgage industry members wondering how serious the CFPB will be when enforcing the Regulation Z loan originator compensation rule (“LO Compensation Rule”) we now have an answer— $13 million dollars serious. ...more

11/8/2013 - Bonuses CFPB Loan Originator Compensation Rule Mortgage Loan Originators Mortgages Regulation Z

CFPB joins interagency statement on qualified mortgage fair lending risks

The CFPB was one of five federal regulators issuing an interagency statement intended to address industry concerns regarding the fair lending risks associated with compliance with the CFPB’s ability-to-repay/qualified...more

10/25/2013 - Ability-to-Repay CFPB Fair Lending FDIC Federal Reserve Mortgages NCUA OCC Qualified Mortgage Rule

Federal Regulators Issue Statement on Qualified Mortgage Fair Lending Risks

Federal regulators have issued an interagency statement intended to address industry concerns regarding the fair lending risks associated with compliance with the Consumer Financial Protection Bureau’s...more

10/25/2013 - Ability-to-Repay CFPB Fair Lending FDIC Mortgages NCUA Qualified Mortgage Rule

CFPB Proposes Final Interim Mortgage Servicing Rule

In keeping with its promise to provide further guidance to the industry on the mortgage loan rules that go into effect in January, the Consumer Financial Protection Bureau (CFPB) recently issued a press release, bulletin, and...more

10/17/2013 - CFPB FDCPA Mortgage Servicers Mortgages

Federal Agencies Propose New Federal Flood Insurance Regulations

The Federal Deposit Insurance Corporation recently approved for release joint proposed regulations to implement provisions of the Biggert-Waters Flood Insurance Reform Act of 2012 (the Act). The proposal would amend the Flood...more

10/11/2013 - Civil Monetary Penalty FDIC Flood Disaster Protection Act Flood Insurance Flooding National Flood Insurance Program Premiums Water Flood Insurance Reform Act

New York Proposes New Force-Placed Insurance Regulations

The New York Department of Financial Services (DFS) recently issued proposed force-placed insurance regulations to reduce premiums and eliminate kickbacks that it claims are pervasive in the industry. The regulations will...more

9/24/2013 - Anti-Corruption Compliance Financial Conduct Authority Fraud Kickbacks Premiums Proposed Regulation

Director Cordray comments on timing of further mortgage rule changes and enforcement approach

While Director Cordray mostly recycled comments he has previously made about the CFPB’s mortgage rules in his remarks today to the American Mortgage Conference, he did offer some newsworthy information....more

9/11/2013 - CFPB Enforcement Mortgages Qualified Mortgage Rule Richard Cordray

Agencies propose changes to QRM exemption and additional exemptions

Federal regulators have issued their long-awaited revised qualified residential mortgage (QRM) proposal. The proposal, which implements Section 941 of the Dodd-Frank Act, was issued jointly by the FDIC, Fed, OCC, SEC and,...more

8/30/2013 - Borrowers CFPB Dodd-Frank FDIC Federal Reserve FHFA HUD Mortgage-Backed Securities Mortgages OCC QRM Standard SEC

76 Results
|
View per page
Page: of 4