Evolving State Supervision: Issues Arising from State Qualification Standards and 'SAFE' Act Licensing, and Coordination with the CFPB
What Happened? In May 2024, the Financial Stability Oversight Council (FSOC or Council) issued a Report on Nonbank Mortgage Servicing (the Report). The Report recognizes the strengths of nonbank mortgage companies (NMCs) and...more
What Happened? Following the release of the Financial Stability Oversight Council (FSOC) Report on Nonbank Mortgage Servicing, Ginnie Mae announced in APM 24-08 that certain large nonbank Ginnie Mae Issuers will now be...more
The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more
A&B Abstract: On April 21, 2023 the Financial Stability Oversight Council (hereinafter “FSOC” or “Council”) issued for public comment (1) a proposed analytic framework setting forth FSOC’s approach to identifying,...more
Raise your hand if you are an independent mortgage banker, a residential mortgage real estate investment trust (“mREIT”) or a nonbank investor in residential mortgage loans that would like to be subject to additional federal...more
The D.C. Circuit Court of Appeals reversed a district court decision dismissing a bank’s challenge to the constitutionality of the CFPB based on lack of standing. The district court had previously concluded that compliance...more