Williams Mullen's Comeback Plan: Part IV - How Banks Think About Loan Defaults: Lessons for Borrowers in Troubled Times
The first three articles in this series took you through the steps for developing a workout strategy. If you have followed those recommendations, you understand where you are and where you want to be. You have also developed...more
If you are a mortgage lender who followed the recommendations in the first article in this series, then you should have a solid grasp of your mortgage portfolio. You have identified the relevant players and their respective...more
A&B Abstract: On January 30, 2023, President Biden informed Congress that the COVID-19 National Emergency (the “COVID Emergency”) will be extended beyond March 1, 2023, but that he anticipates terminating the national...more
With interest rates rising and inflation and energy prices at record levels, the government, major mortgage lenders and the UK FCA have agreed a range of measures that firms can use to support their existing mortgage...more
The CFPB recently issued a Request for Information Regarding Mortgage Refinances and Forbearances (RFI) Comments on the RFI will be due 60 days after publication in the Federal Register....more
In This Issue. The House of Representatives voted to pass a Congressional Review Act resolution repealing the Office of the Comptroller of the Currency’s (OCC) “true lender” rule; the Consumer Financial Protection Bureau...more
Bradley is proud to share the following information collected from the live polls presented at its weekly COVID-19 Compliance Roundtables. The polling covers hot topics, including forbearances, deferrals, HUD loss mitigation...more
A&B ABstract: On April 1, 2021, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) issued a Compliance Bulletin and Policy Guidance (the “Bulletin”) on the Bureau’s supervision and enforcement priorities with...more
In response to the coronavirus pandemic, the federal government passed the CARES Act, which provides a number of protections to homeowners unable to pay their mortgages. The CARES Act prohibits any home foreclosures before...more
ACI’s Residential Mortgage Forum is a premier gathering of leading servicers, lenders, external counsel, and regulators engaging in dialogue on how to navigate the very complex residential mortgage enforcement and litigation...more
Mortgage lenders and mezzanine lenders considering amendments to loan documents, forbearance, loan transfers, the exercise of remedies or deeds in lieu of foreclosure, and other loan-related fact patterns will need to revisit...more
Is a Cap on Payday Loan Rates About Protecting the Poor or Eliminating a Service? "Industry representatives say the proposed cap would drive most, if not all, payday lenders out of business and leave their customers...more
In Mortgagee Letter 2020-30 dated September 10, 2020, the U.S. Department of Housing and Urban Development (HUD) provides guidance on the underwriting of applicants for FHA insured mortgage loans who were granted a previous...more
Florida’s Governor Desantis has extended Executive Order Number 20-180 to 12:01 a.m. on October 1, 2020. The Executive Order, titled “Limited Extension of Mortgage Foreclosure and Eviction Relief” provides, in relevant part: ...more
Welcome! Welcome to August’s issue of All Consuming. This month, we are taking a deep dive into discharges in bankruptcy and then reviewing several top news stories in the world of consumer finance. We hope you find value...more
On June 17, New York Gov. Andrew Cuomo signed one of the most far-reaching COVID-19 mortgage assistance state programs yet into law. Affected servicers and lenders will soon need to decide whether they should find a way to...more
On June 16, 2020, the Federal Housing Finance Agency (FHFA) announced the availability of COVID-19 resources for mortgage loan borrowers....more
A proposed piece of COVID-19 relief legislation could have major implications for California lenders and servicers, particularly in the mortgage lending industry, if passed into law. The assembly bill, entitled “COVID-19...more
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
Mortgage lenders beware: The “CARES” Act has features that make enforcement of federally-backed mortgage loans almost impossible during the “covered period” that runs from January 31, 2020, through the later of 120 days after...more
On April 16, 2020, Black Knight Inc., a leading provider of mortgage and lending analytics, reported that 5.5% or 2.9 million homeowners have entered into CARES Act Forbearance Plans. As of May 7, 2020, Black Knight Services...more
Through an amendment to Assembly Bill 2501, California Assembly Banking and Finance Chair Monique Limon has introduced sweeping forbearance legislation that would impact single-family and multifamily mortgages, auto-secured...more
Year In Review - Anand Raman, the head of Skadden’s Consumer Financial Services (CFS) practice, began the conference by providing a summary of notable events and trends over the past year relating to consumer financial...more
In This Issue. The Board of Governors of the Federal Reserve System (Federal Reserve) expanded access to its Paycheck Protection Program Liquidity Facility (PPPLF) to non-bank lenders and expanded the collateral eligible to...more
Amidst the rising number of mortgage loan forbearances due to COVID-19, Ginnie Mae has stepped in to limit the damage to issuers with its PTAP/C19 program....more