Based upon the records of the New York Fed and the Federal Reserve Economic Data (FRED) of the St. Louis Fed, the level of reverse repo activity on June 17th -18th reached unprecedented levels. It was previously reported...more
In the News. On the heels of a lawsuit challenging the Office of the Comptroller of the Currency’s (OCC) recently issued Madden fix/valid when made rule, eight state attorneys general filed suit challenging a similar rule...more
Regulatory Developments - FHFA Announces Principal Reduction Program for Struggling Underwater Homeowners - On April 14, the Federal Housing Finance Agency (FHFA) announced a new Principal Reduction Modification...more
The CFPB sent industry trade groups a letter on October 1, 2015 to address the approach of the Federal Financial Institutions Examination Council (FFIEC) member agencies during the initial months following the implementation...more
By recently releasing yet another revised representation and warranty framework, Fannie Mae and Freddie Mac continued their efforts to assuage the concerns of the lending industry that a default by a borrower poses an unfair...more
The CFPB sent industry trade groups a letter on October 1, 2015 to address the approach of the FFIEC member agencies during the initial months following the implementation of the TILA-RESPA Integrated Disclosure (TRID) rule...more
As November draws closer, the financial services industry is staking out a front row seat in tracking the outcomes of the 2014 midterm elections. The 114th Congress’ legislative agenda in this area will be shaped in large...more
A September 29, 2014 Report of the Joint Federal Reserve/CFPB Office of the Inspector General (OIG) concluded that the CFPB’s rulemaking process generally complies with the requirements of Section 1100G of the Dodd-Frank...more
From my work defending mortgage loan originators, including many homebuilder captives, against mortgage repurchase and indemnification claims, as well in my role as an editor of Bilzin Sumberg’s Mortgage Crisis Watch, I have...more