Jonathan Foxx – Lenders Compliance Group

Flint - Crisis in Mortgage Banking

The deterioration of the infrastructure through the United States is a significant problem – indeed, a national emergency. In 2013 the American Society of Civil Engineers gave America’s dire situation a grade of D+, with a…more

AARP joins PHH v CFPB Battle

In the continuously unfolding saga of PHH Corporation’s ("PHH") battle with the Consumer Financial Protection Bureau ("Bureau"), we now have a well-known advocacy group joining the side of the Bureau. Last month, the AARP…more

Cases and Regulations: 2016 Predictions

I discuss two categories that, though separate in purpose and determinate qualities, are each intrinsic to the way residential mortgage lenders and originators, as well as other financial service entities involved in extending…more

HMDA Highlights

Last month I published an article on the changes coming in Regulation C, the implementing regulation of the Home Mortgage Disclosure Act. I would like to highlight a few of the salient features for you. Essentially, HMDA…more

Recess Appointment Gambit

Some people just won’t take No for an answer! The most recent fool’s errand is offered thanks to the irrepressible, litigious efforts of the State National Bank of Big Spring, Texas, and two advocacy groups, conservative…more

Home Mortgage Disclosure Act – Big Changes on the Way!

The amendments to existing HMDA requirements, effectuated through HMDA’s implementing Regulation C, will be spread over four effective dates between January 1, 2017, and January 1, 2020. However, the key date that contains most…more

Ten Core Competencies of a Compliance Management System

In my view, there are ten core competencies to implementing a Compliance Management System, often referred to by its acronym CMS. The Consumer Financial Protection Bureau requires it, state regulators are now asking for it, and…more

CFPB versus PHH: Impact on Marketing Services Agreements

On November 5th, the Consumer Financial Protection Bureau (“Bureau”) stated in a brief filed with the D.C. Circuit that its $109 million disgorgement order against PHH Corp. in a mortgage reinsurance kickback case met all…more

The CFPB's HMDA Strategy

Last week on October 15th, the Consumer Financial Protection Bureau (“Bureau”) issued the Final Rule (“Rule”) of the Home Mortgage Disclosure Act (“HMDA”). The Rule is hundreds of pages long, providing numerous important changes…more

CFPB Enforcement Actions: Trends and Lessons

Sometimes, it is a good idea to use a chart to describe a relatively complex subject. One such chart that I keep involves noting the CFPB's administrative actions as they relate to the so-called mortgage industry. The exercise…more

Closing Disclosure: Deep Dive – Pages Four and Five

This is the sixth and final article of a six-part series devoted to TILA-RESPA Integration Disclosure. In this sixth part, I will discuss Page Four and Page Five. Through a review of important highlights, I invite you to join me…more

Tolerance for Owner’s Title Insurance

Given the stringent disclosure demands of Regulation Z, the implementing regulation of the Truth in Lending Act, sometimes there is confusion around the tolerances for owner’s title insurance. The confusion stems from a…more

“A” is for Abusive

Financial institutions and other market participants have struggled to understand how the Consumer Financial Protection Bureau defines "abusive" conduct, but a series of enforcement actions has shown that the bureau intends to…more

A Hermeneutical Approach to State Advertising

We are often asked about what is or is not permitted in nonbank advertisements. Many people are aware of the federal guidelines set forth in Regulation Z, the implementation regulation of the Truth in Lending Act. However,…more

Closing Disclosure: Deep Dive – Page Three

This is the fifth article of a six-part series devoted to TILA-RESPA Integration Disclosure. Although the series, structured as White Papers, was initially established with four parts, I have added a fifth Part and a sixth part…more
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Long Beach, New York 11561, United States

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Areas of Practice
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