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Senate Banking Committee Members Propose Fair Access to Financial Services Act

Members of the US Senate Banking Committee recently introduced a bill to create the Fair Access Financial Services Act of 2020, which is aimed to make any practice of discrimination by a financial institution on the grounds...more

OCC Issues Final ‘True Lender’ Rule

The Office of the Comptroller of the Currency (OCC) issued a final rule on October 27 that determines when a national bank or federal savings association (bank) makes a loan and is the “true lender” in the context of a...more

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

CFPB Issues Guidance Regarding Applications for Early Termination of Consent Orders

The Consumer Financial Protection Bureau (CFPB or Bureau) issued a policy statement on October 5 establishing a process to allow for early termination of consent orders. The policy statement is applicable on October 8, 2020....more

CFPB Outlines Small Business Lending Data Collection Rule Proposals

Section 1071 of the Dodd-Frank Act amended the Equal Credit Opportunity Act (ECOA) to require financial institutions to compile, maintain, and submit to the Consumer Financial Protection Bureau (CFPB or Bureau) certain data...more

California Means Business (Regulation) with New ‘Mini-CFPB’ Law

California’s governor is expected to sign into law soon a bill creating a state consumer financial protection agency, the Department of Financial Protection and Innovation (DFPI), which some have called California’s...more

CFPB Proposes New ‘Seasoned’ Qualified Mortgage Category

The Consumer Financial Protection Bureau (CFPB or Bureau) issued a proposed rule on August 18 to create a new category of seasoned qualified mortgages (Seasoned QMs) that, if finalized as written, would carry significant...more

Executive Actions Provide Limited Mortgage, Rental, and Student Loan Relief

As negotiations for a further comprehensive stimulus package drag on in Congress, US President Donald Trump on August 8 signed two executive actions—a combination of a memorandum and an executive order—that purportedly extend...more

Financial Institutions Encouraged to Consider Additional Options for Consumer and Commercial Borrower Accommodations

The Federal Financial Institutions Examination Council (FFIEC) on behalf of its members issued a statement on August 3 setting forth prudent risk management and consumer protection principles for financial institutions as...more

OCC Issues Proposed ‘True Lender’ Rule

The Office of the Comptroller of the Currency (OCC) issued a proposed rule on July 20 that would determine when a national bank or federal savings association (bank) makes a loan and is the “true lender” in the context of a...more

OCC Plans to Introduce Special Purpose National Bank Charter for Payments Companies

In a series of recent interviews (including with the American Bankers Association and a podcast with the ABA Banking Journal), Acting Comptroller of the Currency Brian Brooks discussed the Office of the Comptroller’s (OCC’s)...more

US Supreme Court to Review FTC’s Right to Seek Equitable Monetary Relief

For decades, the Federal Trade Commission has invoked Section 13(b) of the Federal Trade Commission Act to file suit in federal court in pursuit of both injunctive relief and equitable monetary relief....more

FDIC Issues Madden Rule and Affirms ‘Valid When Made’ and ‘Most Favored Lender’ Doctrines

The Federal Deposit Insurance Corporation (FDIC) issued a final rule on June 25 that reaffirms the enforceability of the interest rate terms of loans made by state-chartered banks and insured branches of foreign banks...more

Supreme Court: CFPB’s Structure Is Unconstitutional, Director Must Serve at President’s Pleasure

The US Supreme Court on June 29 ruled in Seila Law v. Consumer Financial Protection Bureau that the Consumer Financial Protection Bureau’s (CFPB’s) structure unconstitutionally insulates the agency from presidential oversight...more

CFPB Issues Interim Final Rule Regarding Loss Mitigation Options for Homeowners Impacted by COVID-19

The Consumer Financial Protection Bureau (CFPB or Bureau) issued an interim final rule (IFR) on June 23, 2020 that temporarily permits mortgage servicers to offer to borrowers impacted by the coronavirus (COVID-19) pandemic...more

CFPB Launches Pilot Advisory Opinion Program, Solicits Comment

On June 18, 2020, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a procedural rule to launch a new pilot advisory opinion (AO) program to publicly address regulatory uncertainty in the Bureau’s existing...more

OCC Madden Rule Is First Step Toward Needed Clarity for Banks Fintechs and Nonbank Lenders

The Office of the Comptroller of the Currency (OCC) issued a final rule on May 29 clarifying that when a national bank or national savings association sells, assigns, or otherwise transfers a loan, interest permissible before...more

Federal Appeals Court Affirms Injunction Against SBA Imposition of PPP Eligibility Requirements

As the Small Business Administration grafts preexisting eligibility rules atop the Paycheck Protection Program, courts step in to expand access. ...more

FHFA Announces Extension on Moratorium on Foreclosures and Evictions; Provides New COVID-19 Forbearance Payment Deferral Repayment...

The Federal Housing Finance Agency (FHFA) announced on May 14 that Fannie Mae and Freddie Mac (the GSEs) are extending their moratorium on foreclosures and evictions until at least June 30, 2020. ...more

COVID-19: What Servicers Should Know About Managing Mortgage Loan Forbearances

Federal and state regulators and Congress continue to release new guidance and requirements to assist mortgage borrowers facing economic hardships resulting from the coronavirus (COVID-19) pandemic. ...more

FTC Settlement May Raise the Compliance Bar for Fintechs

The Federal Trade Commission (FTC) announced a settled action on April 22 with Canadian company RevenueWire (the Company) and its CEO to resolve allegations that the Company assisted and facilitated two tech-support scams...more

FHFA Announces Four-Month Limit to Servicer Advances for CARES Act Forbearance; Fannie Mae and Freddie Mac Will Purchase Qualified...

The Federal Housing Finance Agency (FHFA) announced on April 21 that servicers’ obligation to advance scheduled monthly payments for Fannie Mae and Freddie Mac (the Enterprises) backed single-family mortgage loans in...more

California Executive Orders Provide Consumer and Commercial Relief During COVID-19

In response to the coronavirus (COVID-19) pandemic, California Governor Gavin Newsom has issued two executive orders that place temporary restraints on the ability of landlords to evict residential tenants, authorize local...more

COVID-19 in Texas: Executive Order Closes Nonessential Businesses, Minimizes Social Gatherings

Texas Governor Greg Abbott issued Executive Order GA-14 on March 31, directing every person in Texas to minimize social gatherings and in-person contact with people who do not live in the same household except where necessary...more

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