Jonathan Foxx – Lenders Compliance Group

167 W Hudson Street - Ste 200
Long Beach, New York 11561, United States

  • 516-442-3456
  • 516-706-7070

Culture of Compliance: FinCEN's View

I have been promoting the concept of a Culture of Compliance (“Compliance Culture”) for some time. Indeed, I have written rather extensively about it and lectured on the subject. As recently as February 2014, I published a full…more
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Consumer Complaint Database and Public Narratives

For some time we have known about the Bureau’s “Consumer Complaint Database” (“Database”). The Bureau’s new proposal would expand the “public-facing database” to include “unstructured consumer complaint narrative data”…more
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Consumers in Foreclosure: Kick’em when they're Down!

On July 23, 2014, the Consumer Financial Protection Bureau and the Federal Trade Commission jointly issued an announcement, entitled "CFPB, FTC and States Announce Sweep Against Foreclosure Relief Scammers." It seems that the…more
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Bitcoins and SAR Narratives

You probably know about Bitcoin, unless you have been living in total seclusion for the last few years. The big controversy usually centers on determining if it is legal tender. But imagine if you are confronted with a…more
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The Strange Case of the Shrinking Mini-Correspondent: A Primer on Forensics

A characteristic feature of a predictable event is that it often becomes inevitable. When that happens, no manner of pleadings or remonstrations will undo the already done! It is not as if we did not know that the predictable…more
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The Bureau's Pursuit of Fair Lending

By now it is a known fact that one of the most important features of an examination conducted by the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) is a rigorous review of fair lending compliance. So, given its…more
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Mitigating the Risk of Distributed Denial-of-Service (DDoS) Attacks

On Tuesday, April 1, 2014, Ellie Mae’s systems were compromised by a Distributed Denial-of-Service (DDoS) attack. Resources known to be affected were all Encompass services, including Encompass Docs Solution™, Electronic…more
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Creating a Culture of Compliance

In this article, I outline the key questions that should be asked, the answers to which will determine the extent, depth, and integrity of a culture of compliance. I am going to take you through a set of questions that will form…more
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Diversity and Inclusion

On October 23, 2013, the Federal Agencies announced their “common standards” proposal, entitled Joint Standards for Assessing Diversity Policies and Practices of Regulated Entities (“Proposal”). This is an Interagency Proposal…more
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The Hedgehog and the Fox: A Regulatory Parable

The 7th century BCE Greek lyric poet, Archilochus, observed: "the fox knows many things, but the hedgehog knows one big thing.” Twenty-two centuries later, Erasmus transliterated Archilochus’s dictum by precisely rendering it…more
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Social Media: Consumer Compliance Risk Management Guidance

On December 11, 2013, the Federal Financial Institutions Examination Council (FFIEC) released final guidance (“Guidance”) on the applicability of consumer protection and compliance laws, regulations, and policies to activities…more
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Fair Lending Compliance, Ability-to-Repay and Qualified Mortgages

On October 22, 2013, the Consumer Financial Protection Bureau (Bureau), Office of the Comptroller of the Currency (OCC), Board of Governors of the Federal Reserve System (Board), Federal Deposit Insurance Corporation (FDIC), and…more
| Finance & Banking, Consumer Protection, Real Estate - Residential

Elder Financial Abuse: Prevention and Remedies

I have written about elder financial abuse, and I will keep writing about it until stops. It is unfathomable to me that schemes to defraud the elderly are so pervasive. These seniors are attractive targets for financial…more
| Criminal Law, Finance & Banking, Consumer Protection, Real Estate - Residential, Wills, Trusts, & Estate Planning

HUD's Safe and Rebuttable Qualified Mortgages

The anxiously awaited Proposed Rule (“Rule”) outlining the Qualified Mortgage for FHA loans was published in the Federal Register on September 30, 2013. Given the bland, bureaucratic title Qualified Mortgage Definition for HUD…more
| Consumer Protection, Finance & Banking, Real Estate - Residential

The Mini-Correspondent Channel: Pros and Cons

Several years ago, our firm, Lenders Compliance Group, provided unique guidance to the mortgage division of a bank. The bank wished to build a special origination platform for its mortgage brokers. At that time, the prevailing…more
| Finance & Banking, Consumer Protection, Real Estate - Residential
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Areas of Practice
  • Financial Services
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