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CFPB Proposes New Restrictions on Mortgage Servicers Before Commencing Foreclosures

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

New Jersey Acts to Limit Credit Card Surcharges

New Jersey Gov. Phil Murphy on Aug. 18, 2023, signed into law a bill that limits the surcharges that merchants may charge their customers who choose to pay for goods or services using a credit card and requires disclosure of...more

New York's "Small Business" Commercial Financing Disclosure Law

If you are a nonbank finance company that makes commercial loans of $2.5 million or less in New York or represent such a company, this Holland & Knight alert is for you. There has been a growing concern expressed over the...more

FinCEN Seeks Public Input to Reduce Vulnerability of Real Estate Market to Money Laundering

The Financial Crimes Enforcement Network (FinCEN) issued an Advance Notice of Proposed Rulemaking (Notice) on Dec. 9, 2021, requesting public comment on ways to enhance the transparency of the domestic real estate market...more

New York Imposes Community Reinvestment Act Requirements on Mortgage Bankers

New York enacted a new law on Nov. 1, 2021, extending the requirements in the state's analog to the federal Community Reinvestment Act (CRA Requirements) to New York-licensed mortgage bankers, thereby becoming the third state...more

CFPB Amends Ability-to-Repay/Qualified Mortgage Rule

The Consumer Financial Protection Bureau (CFPB) recently published two final rules revising its Ability-to-Repay/Qualified Mortgage Rule (ATR/QM Rule). The principal purpose of these final rules is to avoid anticipated...more

FDIC Adopts Final Rule Regarding ILC Applications

The Federal Deposit Insurance Corporation (FDIC) approved on Dec. 15, 2020, a final rule that clarifies how it intends to treat applications to insure an industrial bank or industrial loan company (each, an ILC) or to merge...more

Pennsylvania Enacts Law Permanently Authorizing Remote Online Notarizations

Pennsylvania Gov. Tom Wolf signed into law House Bill No. 2370 (Act 97) on Oct. 29, 2020, permanently and immediately authorizing Pennsylvania notaries to conduct remote online notarizations (RONs) – notarizations conducted...more

CFPB Issues New RESPA Section 8 FAQs

In an important new development, the Consumer Financial Protection Bureau (CFPB) on Oct. 7, 2020, announced that it has rescinded Compliance Bulletin No. 2015-15 (Bulletin) regarding the Real Estate Settlement Procedures Act...more

California Legislative Roundup 2020: Financial Services

Notwithstanding a pandemic-induced winnowing of legislative priorities this year, California has passed a handful of new bills to regulate discrete areas of the financial services industry, including student loan servicing,...more

Remote Online Notarization: More States, Including New Jersey, Join the Crowd

At least 43 states have now, by statute or executive order, authorized notaries in their states to conduct remote online notarizations (RONs) on either a permanent or a temporary/emergency basis, with a substantial number of...more

Stakeholders Debate Public Policy Issues Surrounding Consumer Debt in America

A number of diverse stakeholders gathered at George Mason University (GMU) on Nov. 18, 2019, to participate in a program entitled "Consumer Debt in America: What Would Rate Caps and Student Loan Forgiveness Mean?" The debate,...more

Libor Index Discontinuance: Impact on Residential Adjustable-Rate Mortgages

The New York Federal Reserve Bank's Alternative Reference Rates Committee (ARRC) released its recommendations on Nov. 15, 2019, regarding the London Interbank Offered Rate Index (Libor Index) fallback language for new...more

Pennsylvania Gives Telephone Subscribers New Protections Against Telemarketers/Robocallers

Pennsylvania has enacted House Bill (HB) 318,1 which expands and extends the protections given to Pennsylvania residential and wireless telephone subscribers by the 1996 Telemarketer Registration Act (TRA) in connection with...more

New Jersey Passes New Law to Help Student Loan Borrowers: Servicers Should Take Note

New Jersey has enacted a law, P.L. 2019, c. 200 (Act), that is designed to assist potential and existing student loan borrowers in understanding and managing their student loans. Briefly, the Act: 1) authorizes the New Jersey...more

Federal Court: Unlicensed Debt Buyer Violates FDCPA - Is Ruling in Harmony with the New Jersey Consumer Finance Licensing Act?

• The U.S. District Court for the District of New Jersey has denied a defendant's motion to dismiss a putative statewide class action complaint that alleged that the defendant violated Section e(10) of the federal Fair Debt...more

New Jersey Expands Regulation of Mortgage Servicers

• New Jersey Gov. Phil Murphy signed Assembly Bill A-4997 into law on April 29, 2019, dramatically expanding the state's regulation of residential mortgage servicers. • The law requires nonbank finance companies that...more

Remote E-Notarization: Are New Jersey and Pennsylvania About to Join the Club?

• Legislative initiatives are being undertaken in New Jersey and Pennsylvania to join the growing list of states that have authorized the use of remote online notarizations (remote e-notarizations) by state-commissioned...more

New Jersey Improves and Clarifies Its Residential Mortgage Lending Act

• The State of New Jersey, on Aug. 24, 2018, enacted Assembly Bill 2035 that makes significant and important amendments (Amendments) to the Residential Mortgage Lending Act (RMLA), which had not been amended since it was...more

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