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Regulation Z Mortgages Financial Services Industry

Cooley LLP

CFPB Deems Contracts for Deed ‘Credit’ Subject to Regulation Z

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On August 13, 2024, the Consumer Financial Protection Bureau (CFPB) issued an advisory opinion stating that contracts for deed are “credit” under Regulation Z, and therefore subject to its myriad requirements. Unlike a...more

Troutman Pepper

CFPB Advises Against Certain Contract-for-Deed Practices

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This week, the Consumer Financial Protection Bureau (CFPB or Bureau) issued an advisory opinion and a research report addressing contract-for-deed home financing, also known as a “land contract,” “land installment contract,”...more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services Newsletter - July 2024 # 4

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Ballard Spahr LLP

HUD, Fannie Mae and Freddie Mac Issue Reconsideration of Value Guidance to Combat Appraisal Bias

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The U.S. Department of Housing and Urban Development (HUD), through the Federal Housing Administration (FHA), recently issued Mortgagee Letter 2024-07 addressing reconsideration of value (ROV) policies in connection with...more

Venable LLP

CFPB Homes in on Mortgage "Junk Fees"

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Recent releases from the Consumer Financial Protection Bureau (CFPB) show that the mortgage industry is in the crosshairs of the CFPB's campaign against so-called junk fees. Earlier this year, the CFPB indicated its interest...more

Goodwin

CFPB Bemoans “Junk Fees” in Mortgage Servicing

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On April 24, 2024, the CFPB released its Supervisory Highlights, Mortgage Servicing Edition, (Issue 33, Spring 2024) which provides insight on the CFPB’s current focus in examining mortgage loan servicers. According to the...more

Troutman Pepper

9 Consumer Finance Issues to Note From CFPB Report

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In July, the Consumer Financial Protection Bureau published a report highlighting various unfair, deceptive, and abusive acts or practices it claims to have uncovered during its supervisory examinations from July 2022 to...more

Cadwalader, Wickersham & Taft LLP

Consumer Credit and Leasing Thresholds Updated for 2023

For purposes of general applicability of the Truth in Lending Act and Regulation Z to credit transactions and the Consumer Leasing Act and Regulation M for lease transactions, the Consumer Financial Protection Bureau ("CFPB")...more

Ballard Spahr LLP

CFPB/Fed/OCC increase exemption thresholds for appraisal requirement, Regs Z and M (UPDATED)

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The CFPB, Fed, and OCC have announced that they are increasing three exemption thresholds that are subject to annual inflation adjustments.  Effective January 1, 2024 through December 31, 2024, these exemption thresholds are...more

Troutman Pepper

Federal Agencies Announce Increased Regulations Z and M Dollar Thresholds for Exempt Consumer Credit and Lease Transactions, and...

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On November 13, the Consumer Financial Protection Bureau (CFPB) and the Federal Reserve Board (Fed) announced increased dollar thresholds used to determine whether certain consumer credit and lease transactions in 2024 are...more

Ballard Spahr LLP

CFPB annual CARD Act, HOEPA, QM adjustments do not include credit card penalty fees safe harbors (UPDATED)

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The CFPB recently posted on its website a final rule regarding various annual adjustments it is required to make under provisions of Regulation Z (TILA) that implement the CARD Act, HOEPA, and the ability to repay/qualified...more

Ballard Spahr LLP

CFPB Summer 2023 Supervisory Highlights looks at auto origination and servicing, consumer reporting, debt collection, deposits,...

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The CFPB has released the Summer 2023 edition of Supervisory Highlights.  The report discusses the Bureau’s examinations in the areas of auto origination and servicing, consumer reporting, debt collection, deposits, mortgage...more

Orrick, Herrington & Sutcliffe LLP

CFPB seeks feedback on LO comp

On March 10, the CFPB issued a Request for Comment (RFC) seeking feedback on the Regulation Z Mortgage Loan Originator Rules, including the provisions often referred to as the Loan Originator Compensation or “LO Comp” Rule. ...more

Orrick, Herrington & Sutcliffe LLP

CFPB shutters mortgage lender, alleging deceptive advertising

On February 27, the CFPB entered a consent order against a California-based mortgage lender (respondent) for alleged repeat violations of the Consumer Financial Protection Act, TILA (Regulation Z), and the Mortgage Acts and...more

Hudson Cook, LLP

CFPB Bites of the Month - December Top 10

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Each month, we host a 30-minute webinar outlining the month's key announcements and takeaways from the Consumer Financial Protection Bureau (CFPB) for financial services providers to consider. In this month's article, we...more

Holland & Knight LLP

CFPB Issues Final Libor Transition Rules

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The Consumer Financial Protection Bureau (the Bureau) has issued final regulations (Final Regulations) to facilitate the transition away from Libor (the London Interbank Offered Rate) in the consumer credit market and to...more

Troutman Pepper

CFPB Issues the 2021 Mortgage Servicing COVID-19 Rule

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On June 28, the Consumer Financial Protection Bureau (CFPB) issued a final rule to amend Regulation Z’s mortgage servicing requirements in order to “establish temporary special safeguards to help ensure that borrowers have...more

Sheppard Mullin Richter & Hampton LLP

CFPB Issues Mortgage Servicing FAQs

The CFPB recently released new FAQs regarding the Mortgage Servicing Rule and Regulation X and Regulation Z relating to escrow account guidance and analysis. Putting it Into Practice: Some key takeaways include the...more

Goodwin

CFPB Sues Connecticut-Based Mortgage Lender

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On January 15, 2021, the Consumer Financial Protection Bureau (CFPB) announced it had filed suit in the United States District Court for the District of Connecticut against a Connecticut-based mortgage company and three...more

Dechert LLP

CFPB Issues Two Final Rules: A Change to the General Qualified Mortgage Rule and the Seasoned Qualified Mortgage Rule

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The Consumer Financial Protection Bureau (“CFPB”) recently issued two final rules aimed at bolstering the Qualified Mortgage (“QMs”) market. The first final rule amends the general eligibility category of QMs (“General QMs”)...more

Morgan Lewis - All Things FinReg

CFPB Issues Final Rule Extending the Qualified Mortgage ‘GSE Patch’

The Consumer Financial Protection Bureau (CFPB or Bureau) on October 20 issued a final rule to extend the government-sponsored enterprises patch (GSE Patch), i.e., the “temporary qualified mortgage” exemption within the...more

Ballard Spahr LLP

CFPB Extends Seasoned Loan Proposal Comment Deadline by Three Days

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As previously reported, in August 2020 the CFPB issued a proposed rule to create a new seasoned loan qualified mortgage (QM) under the Regulation Z ability to repay rule. Initially, comments on the proposal were due by...more

Ballard Spahr LLP

CFPB Issues Additional Consent Orders for False and Misleading Mortgage Advertising

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Since late July, the CFPB has issued seven consent orders against mortgage companies in which the CFPB asserts that the companies engaged in false and misleading advertising to service members and veterans. ...more

Ballard Spahr LLP

CFPB Issues Promised Seasoned Qualified Mortgage Loan Proposal

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As promised by the CFPB when it issued two Regulation Z ability to repay rule qualified mortgage (QM) loan proposals in June 2020, the CFPB recently issued a proposal to provide for a new seasoned QM loan. Comments will be...more

Ballard Spahr LLP

CFPB Publishes Interpretive Rule Changing HMDA Fields Used to Identify “Underserved” Areas

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On June 23, 2020, the CFPB published a new interpretive rule (the “Interpretive Rule”) to update the Home Mortgage Disclosure Act (HMDA) data fields that are used to identify “underserved” areas. ...more

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