News & Analysis as of

Real Estate Settlement Procedures Act Borrowers Mortgage Servicers

Orrick, Herrington & Sutcliffe LLP

CFPB rescinds COVID-related protections under RESPA Regulation X

On May 16, the CFPB published a Federal Register notice withdrawing its COVID-19-era mortgage servicing protections for borrowers. The CFPB identified two reasons for rescinding this measure: first, the rule was intended to...more

Holland & Knight LLP

CFPB Proposes New Restrictions on Mortgage Servicers Before Commencing Foreclosures

Holland & Knight LLP on

The Consumer Financial Protection Bureau (CFPB) on July 10, 2024, announced a proposed rule that would require servicers to more intently assist borrowers throughout a "loss mitigation review cycle" before being permitted to...more

Orrick, Herrington & Sutcliffe LLP

CFPB bans two companies for reverse mortgage servicing violations

On June 18, the CFPB issued an order against two reverse mortgage servicing companies (along with certain affiliates and subsidiaries), after determining that the companies misrepresented loan defaults and failed to respond...more

Orrick, Herrington & Sutcliffe LLP

District Court clarifies law related to post-foreclosure RESPA communications

Recently, the U.S. District Court for the District of New Jersey ruled that obligations under RESPA extended beyond the issuance of a foreclosure judgment, but dismissed the plaintiff’s other claim under RESPA. ...more

Sheppard Mullin Richter & Hampton LLP

CFPB Cracks Down on Mortgage Servicers, Alleging Harmful Practices Against Older Homeowners

On June 18, the CFPB settled enforcement actions against two mortgage servicers who serviced reverse mortgages on behalf of HUD, for their systemic failure to respond to consumer requests for assistance, resulting in...more

McGlinchey Stafford

Massachusetts Federal Court Dismisses Borrower’s RESPA Claim After Borrower Fails to Plead Actual or Statutory Damages

McGlinchey Stafford on

In April 2024, the United States District Court for the District of Massachusetts held in a matter of first impression that a borrower must allege actual damages to qualify for relief under the Real Estate Settlement...more

Troutman Pepper Locke

Maryland Federal Court Denies Mortgage Servicer’s Motion to Dismiss Borrowers’ RESPA Claim

Troutman Pepper Locke on

The United States District Court for the District of Maryland recently denied a mortgage servicer’s motion to dismiss a putative class action claim pursuant to the Real Estate Settlement Procedures Act (RESPA) § 2605(g),...more

Orrick, Herrington & Sutcliffe LLP

District Court: Servicer’s QWR responses did not violate RESPA

The U.S. District Court for the Western District of Washington recently granted summary judgment in favor of a defendant mortgage servicer related to alleged RESPA violations concerning qualified written requests and notices...more

Troutman Pepper Locke

Fourth Circuit Clarifies What Constitutes a QWR Under RESPA

Troutman Pepper Locke on

On February 22, the Fourth Circuit clarified in a published opinion what communications constitute a qualified written request (QWR) under the Real Estate Settlement Procedures Act (RESPA). The Fourth Circuit held that “where...more

Bradley Arant Boult Cummings LLP

Interplay of the Cares Act's Forbearance Framework and Regulation X's Loss Mitigation Rules

On March 13, 2020, President Donald Trump declared a national emergency in response to the novel coronavirus disease (COVID-19). Shortly thereafter, to assist consumers impacted by the COVID-19 pandemic, Congress passed the...more

Troutman Pepper Locke

MOSLA Claim Cannot Be Predicated on Underlying RESPA Claim When No Injury Exists

Troutman Pepper Locke on

The U.S. Court of Appeals for the Eighth Circuit held that a claim based on an alleged violation of the Minnesota Mortgage Originator and Servicer Licensing Act (MOSLA) cannot be maintained when the MOSLA claim was based...more

Alston & Bird

New Rules on the Horizon: NYDFS Proposes Overhaul to Mortgage Loan Servicer Business Conduct Rules

Alston & Bird on

A complete overhaul of a complicated set of rules means not just changes in the structure of the rules but changes as significant as definitions and as seemingly minor as the end of the business day. ...more

Troutman Pepper Locke

The Fifth Circuit Clarifies RESPA Obligations for Mortgage Servicers and Sends a Warning that RESPA Should Not Be Used as a Weapon...

Troutman Pepper Locke on

In Germain v. US Bank National Association, --- F.3d ---, 2019 WL 1467053 (5th Cir. Apr. 3, 2019), the Fifth Circuit resolved two issues of first impression that will have a significant impact on mortgage servicers defending...more

Bradley Arant Boult Cummings LLP

Part II: Navigating the Maze of Servicing Discharged Debt

Welcome to Part II of our series on the servicing of discharged mortgage debt (catch up on Part I). This part will discuss communications to discharged borrowers and evaluate various disclaimers that can be utilized. The...more

Alston & Bird

Key Mortgage Servicing Takeaways from S. 2155

Alston & Bird on

On May 24, 2018, the President signed the Economic Growth, Regulatory Relief, and Consumer Protection Act into law. A product of rare bipartisanship, the Regulatory Relief Act makes modest reforms to the Dodd–Frank Wall...more

Balch & Bingham LLP

11th Circuit Provides that Postage Fees Incurred for Sending a Request for Information under RESPA are Insufficient to...

Balch & Bingham LLP on

If a mortgage servicer fails to comply with its obligations under the Real Estate Settlement Procedures Act (“RESPA”), 12 U.S.C. 2601, et seq., or its implementing regulations, a borrower may recover “any actual damages . . ....more

Alston & Bird

CFPB Issues Last-Minute Changes to Mortgage Servicing Rules

Alston & Bird on

As we previously reported, on October 19, 2016, the Consumer Financial Protection Bureau (CFPB) published in the Federal Register final amendments to its Mortgage Servicing Rules (Final Rule). The Final Rule, weighing in at...more

Balch & Bingham LLP

Bivens v. Select Portfolio Servicing, Inc. – 11th Circuit Confirms Right of Servicers to Designate in a Reasonable Manner a...

Balch & Bingham LLP on

On August 17, 2017, the Eleventh Circuit issued an opinion in Steven Bivens v. Select Portfolio Servicing, Inc. (No. 16-15119), holding that a borrower must send requests for information to a mortgage servicer’s designated...more

Carlton Fields

Borrowers Misuse RESPA Notice of Error Letter

Carlton Fields on

Effective January 10, 2014, the Consumer Financial Protection Bureau (CFPB) amended Regulation X, which implements the Real Estate Settlement Procedures Act (RESPA). These provisions address, among other things, a servicer’s...more

BakerHostetler

CFPB Releases Fall 2015 Report Touting Recovery of Millions Through Supervisory Actions

BakerHostetler on

On November 3, the Consumer Financial Protection Bureau (CFPB) released its fall 2015 supervisory report concerning enforcement actions from May 2015 through August 2015. The Bureau highlights violations in the mortgage...more

Carlton Fields

CFPB Reports Continued Mortgage Servicing and Other Violations of Consumer Financial Law

Carlton Fields on

In its Supervisory Highlights released earlier this summer, the CFPB reported its examination observations in consumer reporting, debt collection, mortgage origination and servicing, fair lending, and student loan servicing....more

Balch & Bingham LLP

Southern District of Florida Rejects Borrower Attempts to Hold Mortgage Servicers Liable for Alleged Deficiencies in Responses to...

Balch & Bingham LLP on

Increasingly in courts around the country, borrowers have attempted to transform the Real Estate Settlement Procedures Act (RESPA), along with its implementing regulation (Reg. X), into a “Gotcha!” device through which...more

Burr & Forman

Federal Courts Rejecting Hyper-Technical Claims on Reg X Notice of Error/Request for Information Provisions

Burr & Forman on

In Russell v. Nationstar Mortgage, LLC, No. 14-61977-CIV, 2015 WL 5029346, at *5 (S.D. Fla. Aug. 26, 2015), United States District Court Judge Beth Bloom issued litigious borrowers their latest setback in a large scale...more

Bilzin Sumberg

Wells Fargo Ends Marketing Services Arrangements with Builders

Bilzin Sumberg on

Concerned about “increasing uncertainty surrounding regulatory oversight of these types of arrangements,” Wells Fargo is ending all of its roughly 200 mortgage marketing services and desk rental agreements with builders and...more

Goodwin

Sixth Circuit Holds Servicer Not Liable For Violations of Truth in Lending Act

Goodwin on

The United States Court of Appeals for the Sixth Circuit affirmed in part and reversed in part a district court’s dismissal of two claims—one under the Truth in Lending Act, the other under the Real Estate Settlement...more

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