Thomas P. Vartanian

Thomas P. Vartanian

Dechert LLP

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Latest Posts › CFPB


BNA INSIGHTS: Enforcement Actions Decline But Fines Hit Historic Highs in 2014

During 2014, the number of enforcement actions brought by federal banking agencies1 continued a downward trend that began in 2011. Federal banking agencies issued 661 formal enforcement actions, representing more than a 55...more

6/24/2015 - Banking Sector CFPB Choke Point Civil Monetary Penalty Corporate Fines DOJ Enforcement Actions Enforcement Statistics FDIC Financial Institutions FIRREA Foreign Currency Mortgage-Backed Securities RMBS Strategic Enforcement Plan

BNA's Banking Report: Enforcement 2013: Enforcement Actions Continue Three-Year Decline; DOJ Emerges as Major Player

Overall Trends & Outlook - From an enforcement standpoint, 2013 was another historic year in a number of important ways beyond the sheer number of cases, which were again significant. Federal banking agencies1 issued...more

5/29/2014 - Anti-Money Laundering Bank Secrecy Act Banks CFPB DOJ ECOA Enforcement Enforcement Actions FIRREA Risk Management

Impact of Ability-to-Repay and Qualified Mortgage Rules on Residential Mortgage Loan Purchasers, RMBS Participants and Mortgage...

Loan originators, their advisors and service providers are moving rapidly to achieve compliance by January 10, 2014 with the Consumer Financial Protection Bureau’s (“Bureau’s”) new rule, which generally imposes an affirmative...more

10/4/2013 - Ability-to-Repay CFPB Dodd-Frank Investors Mortgages Qualified Mortgage Rule

U.S. Consumer Financial Protection Bureau Acts to Expand Its Authority Over Nonbank Consumer Financial Services Companies

The Consumer Financial Protection Bureau (“Bureau”), pursuant to its authority to extend its supervision to persons that offer or provide any consumer financial product or service that poses a risk to consumers, has adopted a...more

8/15/2013 - CFPB Compliance Dodd-Frank Final Rules Financial Products Financial Regulatory Reform Nonbank Firms

American Bankers Association Real Estate Lending Conference - Qualified Mortgages: A Sea Change For Mortgage Lenders

In This Presentation: - The Qualified Mortgage (QM) Rule - Small Creditor QM Proposal - The Ability-to-Repay (ATR) Rule: What It Says and What It Means - Liability for Failure to Comply with the ATR and QM...more

4/16/2013 - Ability-to-Repay CFPB Disparate Impact Fair Lending HUD Lenders Loans Mortgages Qualified Mortgage Rule Safe Harbors Underwriting

2012 Bank Enforcement Actions Still High, But Significantly Lower Than 2010-11

Originally published in BNA’s Banking Report, 100 BBR 617 on 04/02/2013. Overall Trends & Outlook - In 2012, the federal banking agencies, including the Federal Deposit Insurance Corporation (‘‘FDIC’’), Office...more

4/4/2013 - Anti-Money Laundering CFPB Enforcement Actions Fair Lending FCRA FDIC FinCEN Mortgage Reform OCC OFAC Unfair or Deceptive Trade Practices

U.S. Consumer Financial Protection Bureau Seeks Comments to Proposed Amendments to the Ability-to-Repay Requirements and Qualified...

The U.S. Consumer Financial Protection Bureau (the “Bureau”) has released a proposal (the "Proposal") to amend the Bureau's recently issued final rules (the “Rules”) on the definition of a qualified mortgage (“QM”) and the...more

2/15/2013 - Ability-to-Repay CFPB Exemptions Mortgages Qualified Mortgage Rule Safe Harbors

U.S. Consumer Financial Protection Bureau Issues Rules on Qualified Mortgages and Ability to Repay

Congress in the Dodd-Frank Act responded to concerns about the quality of mortgage loans by establishing incentives for lenders to seek to ensure that borrowers had the ability to repay mortgage loans made to them. In...more

1/16/2013 - Ability-to-Repay Borrowers CFPB Damages Dodd-Frank Foreclosure Lenders Loans Mortgages Penalties Qualified Mortgage Rule Rebuttable Presumptions Safe Harbors Truth in Lending Act (TILA)

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