Richard J. Andreano, Jr.

Richard J. Andreano, Jr.

Ballard Spahr LLP

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CFPB posts 2017 final lists of rural and rural or underserved counties

The CFPB has posted its 2017 final lists of Rural and Rural or Underserved Counties on its website.  The CFPB has previously posted lists of such counties for calendar years 2011-2016. The lists are relevant to...more

11/22/2016 - Banking Sector CFPB Consumer Lenders Mortgages Residential Real Estate Market Rural Areas

CFPB sending HMDA warning letters

The CFPB announced that it is issuing warning letters to 44 mortgage lenders and mortgage brokers stating that it “has information that appears to show that your company may not be in compliance with certain provisions of the...more

10/28/2016 - Banking Sector Banks CFPB Data Collection Disclosure Requirements Dodd-Frank Financial Institutions HMDA Mortgage Lenders Mortgage Servicers Mortgages Regulation C Reporting Requirements

Cordray remarks to MBA signal continued CFPB focus on servicing, likely petition for rehearing in PHH case

In his remarks at the Mortgage Bankers Association’s annual meeting in Boston on October 25, Director Cordray signaled that mortgage servicing will continue to be a focus of CFPB supervisory and enforcement activity, with the...more

10/27/2016 - CFPB Constitutional Challenges Financial Sector Mortgage Bankers Association Mortgage Servicers Mortgages Petition For Rehearing PHH Corp. v CFPB Removal For-Cause Residential Real Estate Market Richard Cordray Single Director TILA-RESPA Integrated Disclosure Rule (TRID)

D.C. Circuit Holds CFPB Structure Unconstitutional, Interpretation of RESPA Not Entitled to Deference

The D.C. Circuit yesterday issued its long-awaited decision in PHH Corporation v. CFPB. In reversing the decision of Consumer Financial Protection Bureau (CFPB) Director Cordray to impose an enhanced penalty of $109 million...more

10/13/2016 - Administrative Proceedings Article II Banking Sector CFPB Constitutional Challenges Dodd-Frank Due Process HUD Insurance Industry Kickbacks Mortgage Insurance Mortgages PHH Corp. v CFPB Referral Fees Reinsurance Removal For-Cause RESPA Single Director Statute of Limitations Statutory Interpretation

CFPB approves FHLMC/FNMA revised uniform residential loan application; collection of HMDA ethnicity and race information in 2017

In a notice published in today’s Federal Register, the CFPB announced that it has given its “official approval” to a revised and redesigned Uniform Residential Loan Application (2016 URLA) and to the collection of expanded...more

9/30/2016 - Banking Sector CFPB Data Collection ECOA Ethnicity Financial Institutions HMDA Housing Market Mortgages Regulation B Regulation C Residential Real Estate Market

CFPB Revises Methodology Statement for Calculating Average Prime Offer Rates

The Consumer Financial Protection Bureau (CFPB) has published a notice in the Federal Register announcing that it has revised its methodology statement for calculating the average prime offer rates (APORs) under Regulations C...more

8/24/2016 - Banking Sector CFPB Financial Institutions Mortgages Real Estate Market Regulation C Regulation Z

CFPB revises methodology statement for calculating average prime offer rates

The CFPB has published a notice in the Federal Register announcing that it has revised its methodology statement for calculating the average prime offer rates (APORs) under Regulations C and Z. Regulation C requires...more

8/11/2016 - CFPB Covered Financial Institutions Mortgage Lenders Mortgages Regulation C Regulation Z Reporting Requirements

CFPB Proposes TRID Rule Modifications

As previously reported, the Consumer Financial Protection Bureau (CFPB) proposed substantive and technical revisions to the TILA/RESPA Integrated Disclosure (TRID) rule, which the CFPB refers to as the "Know Before You Owe"...more

8/4/2016 - Banking Sector CFPB Closing Documents Consumer Lenders Disclosure Requirements Gramm-Leach-Blilely Act Mortgage Lenders Mortgages Property Insurance Property Tax Regulation Z Residential Real Estate Market TILA-RESPA Integrated Disclosure Rule (TRID) Title Insurance

HMDA resources for data collected in 2017 and 2018

As we have reported, the Consumer Financial Protection Bureau (CFPB) released a final rule amending Regulation C, which implements the Home Mortgage Disclosure Act (HMDA), requiring “Covered Institutions” to report certain...more

7/22/2016 - CFPB Disclosure Requirements FFIEC Filing Requirements HMDA HUD Mortgage Lenders Mortgages Real Estate Market Regulation C Reporting Requirements

CFPB, DOJ Settle Fair Lending Claims Involving Allegations of Redlining, Discretionary Underwriting and Pricing, Overt...

The Consumer Financial Protection Bureau (CFPB) and Department of Justice (DOJ) recently announced a proposed consent order with BancorpSouth Bank to settle charges that the bank’s mortgage lending practices violated the Fair...more

7/22/2016 - Banking Sector CFPB Discriminatory Lending Practices DOJ ECOA Fair Housing Act (FHA) Fair Lending Mortgages Race Discrimination Real Estate Market Redlining

CFPB and DOJ Settle Fair Lending Claims Involving Allegations of Redlining, Discretionary Underwriting and Pricing, and Overt...

The Consumer Financial Protection Bureau (CFPB) and U.S. Department of Justice (DOJ) recently announced a proposed consent order with BancorpSouth Bank to settle charges that the bank’s mortgage lending practices violated the...more

7/11/2016 - Banking Sector CFPB Consent Order Consumer Financial Products Discriminatory Lending Practices DOJ ECOA Fair Housing Act (FHA) Financial Institutions Mortgages Popular Race Discrimination Redlining

CFPB Publishes New Annotated Loan Disclosures

In emails sent to CFPB email subscription holders, the CFPB announced the publication of new annotated versions of the Loan Estimate and Closing Disclosure that include citations to sections in Chapter 2 of the Truth in...more

5/31/2016 - Banking Sector CFPB Consumer Financial Products Consumer Lenders Mortgage Lenders Mortgages Regulation Z TILA-RESPA Integrated Disclosure Rule (TRID) Truth in Lending Act (TILA)

CFPB Publishes New Annotated Loan Disclosures

In emails sent to CFPB email subscription holders, the CFPB announced the publication of new annotated versions of the Loan Estimate and Closing Disclosure that include citations to sections in Chapter 2 of the Truth in...more

5/16/2016 - CFPB Closing Documents Disclosure Requirements Dodd-Frank Mortgages TILA-RESPA Integrated Disclosure Rule (TRID) Truth in Lending Act (TILA)

CFPB publishes two resources for small creditors

The CFPB recently published a fact sheet for small creditors operating in rural or underserved areas. As we have reported, the CFPB issued a final rule, which became effective on January 1, 2016, revising the definitions of...more

5/4/2016 - Banking Sector CFPB Qualified Mortgage Rule Regulation Z Rural Areas Small Credit Institutions Truth in Lending Act (TILA)

CFPB Issues Second Rule to Implement the HELP Act, Expanding Qualified Mortgage Coverage for Lenders in Rural and Underserved...

As we have addressed, Congress passed the Helping Expand Lending Practices in Rural Communities Act of 2015 (HELP Act) on December 4, 2015, in efforts to expand the designation of additional areas as being "rural" under...more

4/15/2016 - Ability-to-Repay CFPB Comment Period Escrow Accounts Final Rules HELP Act Mortgages New Legislation Regulation Z Rural Areas Truth in Lending Act (TILA)

CFPB issues second rule to implement the HELP Act, expanding Qualified Mortgage coverage for lenders lending in rural and...

As we have addressed, Congress passed the Helping Expand Lending Practices in Rural Communities Act of 2015 (HELP Act) on December 4, 2015, in efforts to expand the designation of additional areas as being “rural” under...more

3/31/2016 - Ability-to-Repay CFPB Mortgages Qualified Mortgage Rule Regulation Z Residential Real Estate Market Rural Areas Rural Development Truth in Lending Act (TILA)

CFPB Staff Presents TRID Rule Webinar

The Consumer Financial Protection Bureau (CFPB) staff presented an informational webinar on March 1, 2016, to address several issues with the TILA/RESPA Integrated Disclosure (TRID) rule in connection with...more

3/22/2016 - CFPB Construction Industry Construction Loans Mortgages Residential Real Estate Market TILA-RESPA Integrated Disclosure Rule (TRID)

CFPB invites comments on “Application Process for Designation of Rural Area under Federal Consumer Financial Law”

As we previously addressed, the CFPB issued a final rule to expand the definition of “rural areas” under Regulation Z with regard to the authority of small creditors to make certain qualified mortgage loans under the ability...more

2/24/2016 - CFPB Comment Period Escrow Accounts Final Rules HELP Mortgage Lenders Regulation Z Rural Development

TRID Rule Technical Correction?

In the Federal Register the Consumer Financial Protection Bureau (CFPB) published a correction to the TILA/RESPA Integrated Disclosure (TRID) rule supplementary information as published on December 31, 2013, with regard to...more

2/22/2016 - CFPB Escrow Accounts HOA Dues Mortgages Property Tax TILA-RESPA Integrated Disclosure Rule (TRID)

Federal Reserve Repeals Regulation AA, Proposes Repeal of Regulation C

The Federal Reserve Board (Board) is repealing Regulation AA, which includes the Board's credit practices rule, effective March 21, 2016. The Board is also proposing to repeal its Regulation C, which historically implemented...more

2/19/2016 - Banks CFPB Comment Period Dodd-Frank Federal Reserve FTC Act HMDA Mortgages Regulation AA Regulation C

TRID rule technical correction?

In yesterday's Federal Register the CFPB published a correction to the TILA/RESPA Integrated Disclosure (TRID) rule supplementary information as published on December 31, 2013 with regard to property taxes and certain similar...more

2/11/2016 - CFPB Property Tax TILA-RESPA Integrated Disclosure Rule (TRID)

CFPB Construction Loan "Fact Sheet" Falls Far Short of Necessary Guidance

The Consumer Financial Protection Bureau (CFPB) has issued a "fact sheet" regarding the disclosure of construction-to-permanent loans under the TILA/RESPA Integrated Disclosure (TRID) rule, which the CFPB refers to as the...more

1/25/2016 - CFPB Construction Industry Construction Loans Popular Regulation Z TILA-RESPA Integrated Disclosure Rule (TRID)

CFPB construction loan “fact sheet” falls far short of necessary guidance

The CFPB has issued what it calls a “fact sheet” regarding the disclosure of construction-to-permanent loans under the TILA/RESPA Integrated Disclosure (TRID) rule, which the CFPB refers to as the Know Before You Owe rule....more

1/16/2016 - CFPB Construction Loans Disclosure Requirements Mortgages TILA-RESPA Integrated Disclosure Rule (TRID)

CFPB seeks input on HMDA resubmissions

The CFPB has issued a request for information (RFI) seeking information on what changes to the CFPB’s HMDA Resubmissions Guidelines may be appropriate. The RFI responds to comments received by the CFPB in connection with its...more

1/11/2016 - Banking Sector CFPB HMDA Mortgages Request For Information

CFPB responds to industry concerns about TRID rule liability

Reacting to reports of investors refusing to purchase loans based on various, often technical, violations of the TILA/RESPA Integrated Disclosure (TRID) rule, the Mortgage Bankers Association (MBA) sent a letter to the CFPB...more

12/31/2015 - CFPB Investors Mortgage Bankers Association Mortgages TILA-RESPA Integrated Disclosure Rule (TRID)

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