Jonathan Foxx – Lenders Compliance Group

When does the "foreclosure clock" start ticking?

One of the cases I have been monitoring is U.S. Bank NA v Bartram, which had been argued before the Florida Supreme Court (“Supreme Court”). The issue at bar concerns the statute of limitations for filing a foreclosure suit. I…more
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Compliance Bulletin and Policy Guidance 2016-02 – Service Providers: Questions and Answers

On Wednesday, October 26, 2016, the CFPB issued updated guidance on service providers, based on its previously issuance titled CFPB Bulletin 2012-03, Subject: Service Providers (“Bulletin”), that had been issued on April 13,…more
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Cybersecurity – A Model Approach

As some of you know, Lenders Compliance Group is the first risk management firm in the country to provide both a risk assessment and a disaster recovery plan for banks and nonbanks. The goal is to make the due diligence approach…more
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“First thing we do, let’s kill all the regulators!”

“First thing we do, let’s kill all the regulators!” Actually, Shakespeare's exact line is ''The first thing we do, let's kill all the lawyers.'' This famous exhortation was stated by Dick the Butcher in Henry VI. Dick the…more
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Wells Fargo, A Predator's Tale

It seems it all comes down to money, sooner or later. Anthropologists have long known that we are a predatory species. Our laws and rules are meant not as guides to decent behavior but to keep our primal instincts in check. And…more
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Flipping the Bird at the CFPB!

Do you really want to tell the Consumer Financial Protection Bureau (CFPB) that it doesn’t regulate you? Before flipping the bird at the CFPB, a company had better do some deep and serious deliberations! Take the case of…more
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Going Rogue

There has been a lot of media attention recently about the political class endeavoring to trim the CFPB’s sails. It seems like many of these politicians have taken the view that the CFPB is an out-of-control agency which should…more
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Advertising Compliance-Getting Ready for the Banking Examination (Part II) - Risk Assessments

Just as an examiner will review the advertising materials using various metrics and means, so also should the mortgage loan originator use three tools to ensure compliance with advertising rules. The tools are: -…more
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Advertising Compliance: Getting Ready for the Banking Examination

Advertising is often central to a loan originator’s marketing plans. After all, if prospective borrowers can’t even find you when they need mortgage loans, there’s nothing left but word of mouth, dropping off bagels at real…more
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Too Big to Fail: End Run around a Bank Run

A startling feature of Dodd-Frank is the impression it gives that “Too Big to Fail” - otherwise known as “TBTF” - has been legislatively fixed. The impression is quite misleading. Sort of like the impression that some bank…more
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Skating into the Mortgage Meltdown

The mortgage meltdown goes on and on. Like a nuclear explosion that propagates in a gigantic, lethal plume and roils laterally in wave after wave across a huge landscape, leaving death and destruction in the wake, the financial…more
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Going after the Big Cheese (PHH takes on CFPB’s Director)

As many of you know, I have been following the PHH dispute with the CFPB virtually from its inception. Although PHH is a large organization, let’s face it, this is still like a mouse (PHH) squeaking at an elephant (CFPB)! The…more
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Marketplace Lenders: The CFPB’s Surveillance Begins

Marketplace lenders have been quite a bit in the news these days. Just about every aspect of this business model is being looked at by investors and regulators – particularly the regulators and most particularly the…more
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The CFPB Giveth, and the CFPB Taketh Away

Last Thursday we got a glimpse of the new normal for creating new technologies in the mortgage space. The CFPB issued a policy statement about providing a “no action letter” to companies seeking to develop and implement new…more
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Too Big to Fail: A Wayward Path

I take no great pride in stating that I have actually read the entire Dodd-Frank Act - 2,300 pages. It was a brutal read, but I plotted it, graphed it, bookmarked it, highlighted it, cross-referenced it, and set up an extensive…more
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Contact

New York, United States

  • 866-602-6660 Ext:.100
  • 516-706-7070

Areas of Practice
  • Financial Services
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