Topics In This Issue:
- CONSUMER FINANCE
- CREDIT CARDS
- PRIVACY/DATA SECURITY
- CRIMINAL ENFORCEMENT
- Excerpt From FEDERAL ISSUES:
CFPB Publishes Proposed Mortgage Servicing Standards. On September 17, the Consumer Financial Protection Bureau published in the Federal Register a series of rules proposed last month under the Truth in Lending Act and the Real Estate Settlement Procedures Act that would impose new requirements on all residential mortgage servicers. The CFPB's proposed rules would incorporate elements of many of the servicing standards contained in the various enforcement action settlements with major servicers over the past two years, including standards regarding periodic statements, force-placed insurance, single point of contact and loss mitigation procedures. Public comment is due on the core aspects of the proposed rules by October 9, 2012. BuckleySandler has prepared a Special Alert that provides a detailed review of the CFPB's proposed servicing rules.
FDIC to Host Teleconferences on CFPB Proposed Mortgage Rules. On September 18, the FDIC announced in Financial Institution Letter FIL-39-2012that it plans to host two teleconferences in the coming weeks to discuss the CFPB's mortgage-related proposed rules. The teleconferences will be conducted by staff from the FDIC's Division of Depositor and Consumer Protection and are being offered to officers and employees of FDIC-supervised institutions. The first call will take place on September 27, 2012 and will cover (i) mortgage origination standards, (ii) appraisals for "higher-risk" mortgages, (iii) ECOA appraisal requirements, and (iv) mortgage servicing standards. On October 10, 2012, FDIC staff will discuss (i) RESPA/TILA mortgage disclosure integration, (ii) qualified mortgages and the ability to repay standard, (iii) escrow requirements for "higher-priced mortgage loans", and (iv) high-cost HOEPA loans.
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