BuckleySandler LLP

1250 24th Street, NW Suite 700
Washington, D.C. 20037, United States

Contact: Ezra Crawford

  • 202•349•8000
  • 202•349•8080

Fannie Mae Issues Fact Sheet on Prior Derogatory Credit Event Policies

On September 8, Fannie Mae published a fact sheet about borrower eligibility after a derogatory credit event. The fact sheet reviews Fannie Mae’s recently updated policy related to the minimum waiting periods following a…more
| Bankruptcy, Finance & Banking, Real Estate - Residential

Fannie Mae Authorizes Servicers To Waive Deficiency Judgment Rights, Announces Other Servicing Policy Updates

On September 8, Fannie Mae advised in Servicing Guide Announcement SVC-2014-16 that servicers now have discretion to waive Fannie Mae’s deficiency judgment rights if doing so will help resolve foreclosure delays based upon…more
| Finance & Banking, Real Estate - Residential

Foreclosure of DC Condominium Association’s Lien for Unpaid Assessments Extinguishes First Mortgage

(Chase Plaza Condominium Association, Inv. V. JP Morgan Chase Bank, No 13-CV-623 & 13-CV-674, decided August 28, 2014). In a case of first impression, the District of Columbia Court of Appeals held that a condominium…more
| Finance & Banking, Real Estate - Residential

Fannie Mae Announces Selling Guide Updates

On August 26, Fannie Mae issued Selling Guide Announcement SEL-2014-11, which advises that Fannie Mae is retiring two standard Fannie Mae ARM plans—ARM Plan 1445 and ARM Plan 1446—because certain revisions to Regulation Z and…more
| Labor & Employment Law, Finance & Banking, Real Estate - Residential

Federal District Court Defers To HUD On Disparate Impact Rule Burden-Shifting Framework

On September 3, the U.S. District Court for the Northern District of Illinois declined to invalidate to the burden-shifting framework established by HUD in its 2013 disparate impact rule, but remanded to HUD for further…more
| Finance & Banking, Insurance, Real Estate - Residential

Missouri Assembly Overrides Governor’s Veto Of Installment Lending Bill

On September 10, the Missouri General Assembly voted to override Governor Jay Nixon’s veto of SB 866, which defines traditional installment loans as “fixed rate, fully amortized, closed-end extensions of direct consumer loans”…more
| Conflict of Laws, Elections & Politics, Finance & Banking

SDNY Rejects Challenge To New York City’s Responsible Banking Law

On September 9, the U.S. District Court for the Southern District of New York dismissed an industry group’s challenge to a New York City ordinance that requires banks doing business with the city to report certain information…more
| Finance & Banking

FinCEN Rules Regulations on Money Services Businesses Do Not Apply to ISOs and Exempt Payment Processors

On August 27, FinCEN issued FIN-2014-R009, an administrative ruling clarifying that Independent Sales Organizations (“ISOs”) and exempt payment processors are not money transmitters subject to Bank Secrecy Act (“BSA”)…more
| Finance & Banking

FHFA Proposes Revised Eligibility Requirements for FHLB Membership

On September 2, the Federal Housing Finance Agency (FHFA) issued a proposed rule that would revise the requirements for financial institutions to apply for and retain membership in the Federal Home Loan Banks (FHLB)…more
| Finance & Banking, Real Estate - Residential

Department of Education Publishes Intent to Establish a Negotiated Rulemaking Committee to Develop Pay as You Earn Expansion Regulations

On September 3, the Department of Education (the “Department”) announced its intent to establish a negotiated rulemaking committee to help develop regulations to allow more student borrowers of Federal Direct Loans to use the…more
| Education, Finance & Banking

OCC Updates Electronic Fund Transfer Act Booklet

On August 28, the OCC issued Bulletin 2014-43, which announces the issuance of a revised “Electronic Fund Transfer Act” booklet of the Comptroller’s Handbook. This booklet replaces the similarly titled booked issued in October…more
| Finance & Banking, Consumer Protection

CFPB Warns Credit Card Issuers Regarding Offering Promotional APRs

On September 3, the CFPB published Bulletin 2014-02 warning credit card issuers of the risk of engaging in deceptive or abusive acts and practices in connection with solicitations offering a promotional annual percentage rate…more
| Finance & Banking, Consumer Protection

New AAA Consumer Arbitration Rules Effective September 1

The American Arbitration Association (AAA) launched new Consumer Arbitration Rules that became effective on September 1. The new Consumer Arbitration Rules, comprised of 55 rules, replace the eight rules in the Consumer-Related…more
| Alternative Dispute Resolution (ADR)

FinCrimes Update - August 2014 Summary, Volume 1, Issue 6

In This Issue: - BSA/AML & OFAC - Virtual Currency & Payment Systems - FCPA & Anti-Corruption - Criminal Enforcement - Excerpt from BSA/AML & OFAC: FINCEN PUBLISHES LONG-AWAITED PROPOSED…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade, Real Estate - Residential, Securities Law

OCC Finalizes Heightened Standards for Large Financial Institutions

On September 2, the OCC published its final guidelines to purportedly strengthen the governance and risk management practices of large financial institutions. The guidelines provide that covered institutions should establish and…more
| Finance & Banking
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