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
A&B Abstract: As we have previously reported, effective August 3 the Office of the Comptroller of the Currency’s (“OCC”) has issued a final rule affirming the “valid-when-made” doctrine while dismissing the Second Circuit...more
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
A&B ABstract: A recent letter from Consumer Financial Protection Bureau (“CFPB”) Director Kathleen Kraninger provides clues about the potential future of the so-called “QM Patch.”...more
New York’s amended mortgage loan servicer regulations are a substantial departure from previous versions and could go beyond federal rules. Our Financial Services & Products Group delves into technicalities and ramifications...more
A&B ABstract:
A new rule from the federal banking regulators reduces the number of residential mortgage transactions for which an appraisal is required. ...more
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
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
It’s hot out there and the market’s even hotter! Cool off with the latest issue of the Structured Finance Spectrum, our newsletter featuring what’s new and newsworthy in structured finance.
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A&B Abstract: With the January 2021 expiration of the so-called “QM Patch” looming, what courses of action are available to the CFPB?...more
Sometimes common sense rules the day. Our Financial Services & Products Group discusses a case of first impression in Ohio that will allow the mortgage industry to rely on the Consumer Financial Protection Bureau’s...more
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
SECURITIZATION SIDE NOTES – EU Risk Retention: Did This Come with a Gift Receipt? We’d Like to Return It -
A new year brings new laws and regulations into effect, in this case a complicated and confusing gift from our...more
PRACTITIONER NOTES – Frankenstein’s Monster? Rosemary’s Baby? The Twins from the Shining? How Lenders are thinking about the Delaware Division Statute and Division LLCs -
Recent amendments to the Delaware LLC Act (the...more
The Consumer Financial Protection Bureau comes through with a solution to a particularly vexing disclosure rule. Our Financial Services & Products Group shines some light on the new TRID Rule that solves several problems but...more
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
A continuation of the market trends from last year can be expected in 2018. Structured finance and securitization markets had a period of relative calm in 2017 as new regulations were incorporated into transactions. While no...more
2/7/2018
/ Capital Requirements ,
Consumer Financial Protection Bureau (CFPB) ,
EDGAR ,
Financial Institutions ,
FIRREA ,
Foreclosure ,
Mortgages ,
Securitization ,
Structured Finance ,
Tax Cuts and Jobs Act ,
TILA-RESPA Integrated Disclosure Rule (TRID)
Texans approved a constitutional amendment changing the state’s home equity loan landscape beginning January 1. Our Financial Services & Products Group examines the new law and its implications and limitations....more
On November 2, 2017, the Arkansas Securities Commissioner (ASC) issued a consent order against a financial services company for purchasing and holding “master servicing rights” (commonly referred to as mortgage servicing...more