For those companies who pay attention to the always evolving regulatory environment as we do at Brownstein Hyatt Farber Schreck, you have likely heard the debate regarding the validity of rules promulgated by organizations with recess appointments at their head. To that end, you have likely questioned whether you need to follow the rules laid out by the Consumer Financial Protection Bureau (CFPB) as its director, Richard Cordray, was a recess appointment. The answer is absolutely “YES.”
The CFPB is continuing to publish and enforce its own rules and regulations and will not be deterred by political infighting. Most recently, the CFPB met its January 21, 2013, deadline for issuing new mortgage rules. On February 13, 2013, the CFPB published how it intends to implement those new rules. Companies have until June 2013 and/or January 2014 to meet the deadlines and will likely need every month to implement the significant systematic changes.
Please see full article below for more information.
Firefox recommends the PDF Plugin for Mac OS X for viewing PDF documents in your browser.
We can also show you Legal Updates using the Google Viewer; however, you will need to be logged into Google Docs to view them.
Please choose one of the above to proceed!
LOADING PDF: If there are any problems, click here to download the file.
Topics: Borrowers, CFPB, Lenders, Loans, Mortgages, Recess Appointments, Richard Cordray, TILA
Published In: General Business Updates, Consumer Protection Updates, Finance & Banking Updates, Residential Real Estate Updates
DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
© Brownstein Hyatt Farber Schreck | Attorney Advertising