On June 23, 2020, the Consumer Financial Protection Bureau (CFPB) issued an interim final rule permitting mortgage servicers to offer certain loss mitigation options based on the evaluation of an incomplete loss mitigation...more
On June 16, the Consumer Financial Protection Bureau (CFPB) issued a compliance guide clarifying the credit reporting protections provided by the Coronavirus Aid, Relief and Economic Security (CARES) Act....more
On June 2, 2020, the Consumer Financial Protection Bureau (CFPB) provided additional guidance to remittance transfer providers regarding the Remittance Rule, subpart of Regulation E....more
On June 17, 2020, the Federal Housing Finance Agency (FHFA) announced an extension of its eviction and foreclosure moratorium due to the COVID-19 pandemic until August 31, 2020. This is an extension of FHFA’s May 14 and March...more
6/20/2020
/ Coronavirus/COVID-19 ,
Eviction ,
Financial Distress ,
Foreclosure ,
Landlords ,
Moratorium ,
Mortgagee ,
Mortgages ,
Relief Measures ,
Rent ,
Rental Property ,
State of Emergency ,
Tenants
The Consumer Financial Protection Bureau and the Conference State Bank Supervisors issued joint guidance to mortgage servicers clarifying the forbearance provision of the Coronavirus Aid, Relief and Economic Security (CARES)...more
On June 3, 2020, the Consumer Financial Protection Bureau (CFPB) issued a statement announcing temporary supervisory and enforcement flexibility during the COVID-19 pandemic for credit card issuers regarding electronic...more
On May 13, 2020, the Consumer Financial Protection Bureau (CFPB) issued a Statement on Supervisory and Enforcement Practices Regarding Regulation Z Billing Error Resolution Timeframes in Light of the COVID-19 Pandemic...more
On May 13, Fannie Mae and Freddie Mac both announced a new COVID-19 Payment Deferral workout option. Fannie Mae's Lender Letter LL-2020-07 and Freddie Mac's Bulletin 2020-15 provide detailed requirements on this new deferral...more
On May 14, 2020, the Federal Housing Finance Agency (FHFA) announced an extension of its eviction and foreclosure moratorium due to the COVID-19 pandemic until June 30, 2020. This is an extension of FHFA's March 18 directive...more
On May 13, 2020, the Consumer Financial Protection Bureau (CFPB) issued two sets of FAQs. The first set of FAQs is directed to providers of checking, savings, and prepaid accounts. The second set of FAQs is directed to...more
States are rapidly adapting to social distancing in their approaches to remote notarization. The below chart tracks the steps, special conditions, and considerations on a state-by-state basis. The chart lists states...more
On May 6, 2020, the Consumer Financial Protection Bureau (CFPB) issued FAQs clarifying Regulation B's application to the Small Business Administration's (SBA) Paycheck Protection Program (PPP)....more
On April 29, 2020, the Consumer Financial Protection Bureau (CFPB) issued an interpretive rule clarifying Regulation Z's bona fide personal financial emergency provisions in the context of the COVID-19 pandemic. The CFPB...more
5/7/2020
/ Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
ECOA ,
Emergency Waivers ,
Loans ,
Mortgages ,
Personal Finances ,
Regulation Z ,
Rescission ,
RESPA ,
TILA-RESPA Integrated Disclosure Rule (TRID) ,
Truth in Lending Act (TILA)
Updated on April 28, 2020 -
On April 3, the Federal Reserve, OCC, FDIC, CFPB, NCUA, and the Conference of State Bank Supervisors (Agencies) issued a joint statement intended to provide flexibility to mortgage servicers who...more
On April 21 the Federal Housing Finance Agency (FHFA) announced a new policy for servicer obligations towards Fannie Mae and Freddie Mac loans in forbearance. Under the new policy, servicers are only required to advance four...more
On April 14, federal agencies announced a new interim final rule and interagency guidance relating to appraisals and evaluations for real estate related financial transactions affected by the COVID-19 pandemic....more
Fannie Mae and Freddie Mac have both issued guidance addressing the impact of the COVID-19 pandemic on borrowers with multifamily property mortgages....more
Fannie Mae and Freddie Mac issued several guidance letters and bulletins to sellers and servicers in response to the COVID-19 pandemic....more
On March 27, President Trump signed the Coronavirus Aid, Relief, and Economic Security Act (the CARES Act), legislation intended to help Americans and businesses survive the ongoing public health and economic crisis due to...more
The COVID-19 crisis has led to foreclosure moratoriums at the regulatory, executive, and judicial level. Servicers should consider that compliance with these, regardless of level, may not protect them from later challenges to...more
3/24/2020
/ Coronavirus/COVID-19 ,
Fannie Mae ,
FHFA ,
Financial Institutions ,
Foreclosure ,
Freddie Mac ,
HUD ,
Moratorium ,
Mortgage Lenders ,
Mortgages ,
Relief Measures ,
Statute of Limitations ,
Tolling
The Florida Supreme Court has issued Administrative Order AOSC20-16, which allows oaths to be administered remotely for remote testimony, depositions, and other out-of-court legal testimony, as long as the notary or other...more
Federal and state governments are beginning to issue emergency orders and take other actions related to foreclosure. Below is a summary of those actions to date. We will update this summary as new information becomes...more
3/23/2020
/ Coronavirus/COVID-19 ,
Emergency Response ,
FHFA ,
Governor Hogan ,
Governor Holcomb ,
Governor Kelly ,
Governor Murphy ,
Governor Newsom ,
Governor Sununu ,
HUD ,
State and Local Government ,
State of Emergency
Federal and state governments are beginning to issue emergency orders and take other actions related to foreclosure. Below is a summary of those actions to date. We will update this summary as new information becomes...more
3/21/2020
/ Coronavirus/COVID-19 ,
Emergency Orders ,
Eviction ,
FHFA ,
Foreclosure ,
HUD ,
Moratorium ,
Mortgages ,
Rental Property ,
Suspensions ,
Tenants
Our industry’s commitment to the health and safety of its workforce and the CDC’s social distancing recommendations require we explore ways to minimize physical proximity in employees’ daily tasks. For those in our clients’...more
On Friday January 24th, the Consumer Financial Protection Bureau (CFPB) issued a statement regarding how it will use its supervision and enforcement authorities to pursue abusive acts and practices by providers of consumer...more