News & Analysis as of

Real Estate Settlement Procedures Act

Bradley Arant Boult Cummings LLP

Bradley Comment Letter Highlights Questions Regarding the CFPB’s Statutory Authority to Issue Contemplated Mortgage Servicing...

On July 10, 2024, the Consumer Financial Protection Bureau (CFPB) released a proposal to amend the existing mortgage servicing rules in Regulation X. The substance of the proposal has attracted a lot of attention and...more

Ballard Spahr LLP

DC Attorney General Settles with Four Title Company Joint Venture Organizers

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The District of Columbia (DC) Office of the Attorney General (OAG) recently entered into settlements with four title companies in connection with title company joint ventures that included the companies and real estate agents...more

Sheppard Mullin Richter & Hampton LLP

DC Attorney General Settles with Title Insurance Companies Over Alleged Kickback Scheme

On August 29, the DC Attorney General’s office announced settlements with four title insurance companies over their widespread use of illegal kickbacks in violation of DC’s Consumer Protection Procedures Act (CPPA). Under the...more

Sheppard Mullin Richter & Hampton LLP

CFPB Hits Executive Compensation in Action Against National Mortgage Servicer for Illegal Foreclosure Practices

On August 21, the CFPB entered into a consent order with a nonbank mortgage servicer for mortgage servicing violations and for violating an earlier 2017 CFPB consent order for deficient foreclosure practices. In 2017, the...more

Hudson Cook, LLP

CFPB Takes Action Against Mortgage Servicer for Alleged Order Violations and Servicing Errors

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On August 21, 2024, the CFPB issued a Consent Order against the Company citing alleged failure to provide accurate information about loss mitigation options and improper handling of loan modifications. The Consent Order...more

Goodwin

CFPB Enters Into Consent Order With Mortgage Servicer Resolving Allegations of Improper Foreclosure Practices

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On August 21, 2024, the Consumer Financial Protection Bureau (CFPB)​ announced​ that it entered into a consent order with a​ Florida-based mortgage servicer, resolving allegations related to the mortgage servicer’s...more

McGlinchey Stafford

CFPB Proposes New Rules Aimed at “Streamlining” Mortgage Servicing

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On July 10, 2024, the Consumer Financial Protection Bureau (CFPB or Bureau) proposed a rule it says will streamline mortgage servicing and the loss mitigation process. If enacted, the proposed rule would significantly revise...more

Hudson Cook, LLP

CFPB Bites of the Month - July 2024 - The CFPB Shines Like the 4th of July

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In this month's article, we share some of our top "bites" for the prior and current month covered during the July 2024 webinar....more

Holland & Knight LLP

CFPB Proposes New Restrictions on Mortgage Servicers Before Commencing Foreclosures

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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

Husch Blackwell LLP

Preview of a Post-Chevron World: The Seventh Circuit Upholds Regulation B's Discouragement Prohibition as Consistent with ECOA

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With Loper Bright’s recent death blow to Chevron deference, some commentators have been predicting substantial constriction of the administrative state and the narrowing or limiting of the powers of federal regulators. For...more

Sheppard Mullin Richter & Hampton LLP

CFPB Proposes Revamped RESPA Mortgage Servicing Rules

On July 10, the CFPB announced proposed rules for mortgage servicers, aimed at helping homeowners avoid foreclosures. The new rules, which would modify RESPA and Regulation X’s existing mortgage servicing framework, are...more

Foley & Lardner LLP

Will the End of Chevron Deference Be a Sea Change for Consumer Financial Services Industry?

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On June 28, 2024, the Supreme Court decided Loper Bright Enterprises v. Raimondo, overturning its own 40-year-old Chevron v. Natural Resources Defense Council decision. In Chevron, the Supreme Court articulated the so-called...more

Bradley Arant Boult Cummings LLP

CFPB: Ineffective Loan Servicing Is an Abusive Act or Practice

In a consent order with a reverse mortgage servicer on June 18, 2024, the Consumer Financial Protection Bureau (CFPB) made the argument that failing to effectively service loans is abusive. The groundwork for this line of...more

Goodwin

CFPB Enters into Consent Orders with Reverse Mortgage Servicers for $16.5 Million

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On ​​​​​​​June 18, 2024, the Consumer Financial Protection Bureau (CFPB or Bureau) announced that it has entered into consent orders with two companies totaling $16.5 million in civil penalties and consumer redress​,...more

McGlinchey Stafford

Litigation Byte (May Edition)

McGlinchey Stafford on

The Litigation Byte is the new name and format for McGlinchey’s Commercial Law Bulletin. Our new format will reflect McGlinchey’s national coverage and our expanded footprint while still serving up the digestible, insightful...more

McGlinchey Stafford

New York’s Interest-On-Escrow Law May Not Be Preempted by the National Bank Act

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On May 30, 2024, the Supreme Court reversed the Second Circuit’s holding that New York General Obligation Law § 5–601, which mandates banks to pay borrowers the interest accumulated on a balance held in an escrow account for...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

Hudson Cook, LLP

CFPB Imposes Bans from Reverse Mortgage Servicing, $11.5 Million Restitution, and $5 Million in Civil Money Penalties for...

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The CFPB entered into consent orders with a Home Equity Conversion Mortgage ("HECM," also known as a "reverse mortgage") servicing contractor, its subcontractor, and two of its subcontractor's subsidiaries. The U.S....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

Goodwin

Increased Industry Attention on RESPA Section 8: Escue v. United Wholesale Mortgage, LLC

Goodwin on

On April 2, 2024, a putative class action was brought against United Wholesale Mortgage (UWM) alleging, among other claims, violations of Section 8(a) of the Real Estate Settlement Procedures Act (RESPA). The lawsuit contains...more

McGlinchey Stafford

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

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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

Goodwin

FDIC Announces $1.5 Million Settlement with Arkansas-Based Bank and Employees

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​​​​​​​​On May 17, 2024, the Federal Deposit Insurance Corporation (FDIC) announced a settlement with an Arkansas bank and nine of its employees, resolving allegations that the bank and the employees violated Section 5 of the...more

Husch Blackwell LLP

FDIC's Continued Focus on RESPA Section 8 Violations: What Bank and Non-Bank Lenders Should Know

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It is no secret that the Federal Deposit Insurance Corporation (FDIC) actively monitors its banks for compliance with Section 8 of the Real Estate Settlement Procedures Act (RESPA Section 8). However, in its March 2024...more

Orrick, Herrington & Sutcliffe LLP

FDIC’s Consumer Compliance report outlines most frequently cited violations and observations

On March 28, the FDIC released its March 2024 version of the Consumer Compliance Supervisory Highlights from the previous year, a report that enhanced transparency regarding the FDIC’s consumer compliance supervisory...more

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