In the 2012 edition of its Trade Finance Guide, the International Trade Administration for the first time discussed escrow service as a variation on cash in advance and a payment method available to U.S. exporters. The ITA’s...more
In an effort to summarize the highlights of the U.S. Department of Housing and Urban Development (HUD) LEAN E-mail Blasts that we receive, and rarely have time to review in a timely fashion, we at Pepper are providing this...more
On October 11, the FDIC, the OCC, the Federal Reserve Board, and other federal agencies (collectively the agencies) proposed a rule to implement changes to certain flood insurance regulations required by the Biggert-Waters...more
The Consumer Financial Protection Bureau is gearing up for a busy January, when new regulations directed at the residential mortgage industry are due to be implemented. While lenders scramble to comply with stringent...more
On September 5, HUD issued Mortgagee Letter 2013-29 regarding the application of unused borrower funds from an escrow account on an existing mortgage in FHA-insured refinance transactions. The letter states that mortgagees...more
Between December 2012 and January 2013, Efficient Services Escrow Group of Irvine, Calif., had $1.5 million drained from its account with First Foundation Bank. Three separate wire transfers were made to accounts in Russia...more
From time to time, the Department of Business Oversight posts warnings about fraudulent on-line escrow companies. According to the Department, these fraudsters use stolen identities and credit card numbers to open a Web...more
Most commercial or industrial buyers of contaminated property, and virtually all lenders at contaminated sites, require sellers to either obtain a no-further-remediation letter (NFR) themselves, place money in escrow in an...more
On June 4, the CFPB published an update to its exam procedures for the new mortgage regulations issued in January 2013 relating to appraisals, escrow accounts, and compensation and qualifications for loan originators....more
This week, the CFPB published an update to its examination procedures to account for the new mortgage regulations going into effect in January 2014. The update includes Interim TILA Examination Procedures and Interim ECOA...more
This case involved the unusual situation of a dual proceeding in the Court of Chancery and the Superior Court. In the Chancery action, the Sellers of Iron Data Solutions, LLC (“Iron Data”) sought to compel disbursement of...more
Each July, nearly everyone who owns real estate, motor vehicles or business equipment in Connecticut owes municipal taxes. Paying later means paying more. Interest runs at 1.5 percent per month (18 percent annually), state...more
On May 16, the CFPB issued a final rule clarifying and making technical amendments to its Escrows Final Rule in January of this year....more
On May 16, the CFPB issued a final rule clarifying its January 2013 final rule on escrow account requirements for first-lien higher-priced mortgage loans (HPMLs). ...more
The Consumer Financial Protection Bureau (“CFPB”) recently issued a final rule clarifying the 2013 Escrows Final Rule issued by CFPB on January 10, 2013. The CFPB indicates that the clarifying and technical amendments to the...more
When I joined the Department of Corporations, it had no website. I remember reviewing possible designs for a site. Now, it seems hard to imagine that there was a time when state agencies didn’t have websites. Today, the...more
The CFPB amends its Escrow Requirements Under the Truth in Lending Act Rule -
On Thursday, May 16, 2013, the Consumer Financial Protection Bureau (the "CFPB") adopted clarifying and technical amendments to its Escrow...more
A stock purchase agreement is the main transaction document for a stock acquisition. It governs the transfer of title and sale of shares of a corporation’s stock to the purchaser. The document sets forth the critical details...more
On Wednesday, April 10, 2013, the Commodity Futures Trading Commission (the "CFTC") and the Securities and Exchange Commission (the "SEC") jointly issued final rules and guidelines that will require certain regulated entities...more
On April 12, the CFPB issued a proposed rule clarifying and making technical amendments to the 2013 Escrows Final Rule issued in January relating to mandatory escrow requirements for certain mortgage loans. Comments on the...more
Fed Proposal on Annual Assessments - On April 15, the Fed requested comment on a proposed rule to establish an annual assessment for bank holding companies and savings and loan companies with $50 billion or greater in total...more
The FDIC has scheduled the following three free teleconferences on the CFPB’s new mortgage-related rules for officers and employees of FDIC-supervised institutions...
In This Presentation:
1. Why were changes needed?
2. How are things changing?
3. The process of change
4. Amendments in place now
5. What is still to change?
- 2nd Draft Amendment
- 3rd Draft...more