Jonathan Foxx – Lenders Compliance Group

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

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

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

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

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

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

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

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

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

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
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