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States Impose Commercial Financing Disclosure Requirements

What Happened: In a little-noticed development, eight states have enacted legislation that requires specific disclosures for commercial non-real estate secured financing transactions....more

Structured Finance Spectrum – Winter 2024

Welcome to the latest edition of the Spectrum, covering hot-topic issues in the structured finance markets in the U.S. and UK. This edition features the shifting single-family rental landscape, what’s next for EDGAR, and...more

Structured Finance Spectrum - Summer 2023

Welcome to the latest edition of the Spectrum, covering hot-topic issues in the structured finance markets in the U.S. and UK. This edition features smooth sailing through safe harbors, the English Court doing the cross-class...more

Structured Finance Spectrum – July 2022

Welcome to the latest edition of the Spectrum, covering hot-topic issues in the structured finance markets in the U.S. and UK. Guest edited by our London team, this edition focuses on the opportunities that come from stressed...more

Juneteenth Holiday Raises Tricky TRID Disclosure Issues

Creditors will need to remember to take into account the newly recognized Juneteenth holiday when serving notice to consumers. Our Financial Services & Products Group explains this sudden new dynamic and what it means for the...more

Fannie Mae and Freddie Mac Sunset the QM Patch

The qualified mortgage (QM) rules have become a world of contradictions. Our Financial Services & Products Group investigates how the residential mortgage markets can thread the needle between new rulings from Fannie Mae and...more

CFPB Retires the “QM Patch” and Revises QM Rules

A&B ABstract: In a significant final rulemaking with potentially far-reaching consequences for the residential mortgage markets, the Consumer Financial Protection Bureau (“CFPB”) is terminating the “QM Patch” and...more

OCC’s Final “True Lender” Rule Takes Effect

A&B ABstract: On October 27, 2020, the Office of the Comptroller of the Currency (“OCC”) issued a noteworthy final rulemaking that sets forth when a national bank or federal savings association originates a loan and is deemed...more

OCC Rule Affirms Valid-When-Made Doctrine

A&B ABstract: On May 15, the Office of the Comptroller of the Currency (“OCC”) issued a final rule, effective August 3, 2020, addressing the “valid-when-made” doctrine. ...more

6/8/2020  /  Loans , OCC , Valid When Made Doctrine

CFPB Rules Permit Qualified Mortgage “Cures”

A&B Abstract: What happens when a proposed qualified mortgage is later discovered to have points and fees in excess of the statutory threshold? ...more

QM Patch Update: CFPB Proposes to Let Patch Expire

A&B Abstract - The CFPB has issued an Advance Notice of Proposed Rulemaking regarding the fate of the “QM Patch,” indicating that it will not extend the “QM Patch” permanently....more

California Consumer Loans Exempt from Usury May Be Deemed “Unconscionable”

Our Financial Services & Products Group delves into why a little-noticed California Supreme Court ruling could cause providers of financial consumer products in California serious headaches. - Can the interest rate render...more

Pennsylvania Offers Clarity for Holders of Mortgage Servicing Rights

Our Financial Services & Products Group summarizes Pennsylvania’s answers to frequently asked questions about its new licensing requirements for mortgage servicers. - Definition of “mortgage servicer” - The FAQs -...more

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