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CFPB Announces Final Rule Closing “Overdraft Loophole” Created by TILA 

On December 12, 2024, the Consumer Financial Protection Bureau (CFPB) announced its final rule, redefining overdraft fees as finance charges in order to limit overdraft fees. The final rule seeks to regulate how overdraft...more

TD Bank’s Historic $3.1B Money Laundering Settlement a Warning to All Financial Institutions

On October 10, 2024, Attorney General Merrick Garland announced that TD Bank agreed to pay over $1.8 billion in penalties to resolve the U.S. Department of Justice’s (DOJ) investigation into money laundering and Bank Secrecy...more

Renewed Federal Scrutiny for Nonbank Mortgage Companies

Based on a recent report from the Financial Stability Oversight Council (FSOC), nonbank mortgage companies (NMCs) need to prepare for additional regulatory scrutiny from both state and federal regulators. In the report, FSOC...more

CFPB Supervisory Highlights, Mortgage Servicing Edition, Shed Light on Agency Priorities – “Junk Fees” and Loss Mitigation

The CFPB released its Supervisory Highlights, Mortgage Servicing Edition on April 24, 2024. These highlights share the CFPB’s findings from supervisory examinations completed between April 1, 2023, and December 31, 2023....more

Fannie Mae Issues Fair Servicing Best Practices Guide

This week, in line with the CFPB’s ever-increasing focus on fair lending, Fannie Mae issued a Fair Servicing Best Practices Guide to promote “servicer awareness of fair servicing best practices.” Taking a big picture...more

CFPB Analyzes the Financial Health of Rural Borrowers in the South

On June 21, 2023, the CFPB released two Data Spotlight reports focused on the Southern states, entitled “Banking and Credit Access in the Southern Region of the U.S.” and “Consumer Finances in Rural Areas of the Southern...more

CFPB Highlights Banking and Credit Hurdles for Minority and Rural Borrowers in the South

On June 21, 2023, the CFPB released two Data Spotlight reports focused on the Southern states, entitled “Banking and Credit Access in the Southern Region of the U.S.” and “Consumer Finances in Rural Areas of the Southern...more

CFPB Issues Guidance to Lenders and Collectors on So-Called Zombie Second Mortgages

On April 26, 2023, the CFPB issued an advisory opinion clarifying that a debt collector who brings or threatens to bring a foreclosure action to collect a time-barred mortgage debt may violate the Fair Debt Collection...more

Mortgage-Related Complaints to CFPB in 2022

On March 31, 2023, the CFPB released its annual consumer complaints report. Although there was a significant increase in non-mortgage related complaints, the volume of mortgage-related complaints decreased compared to...more

CFPB Updates Mortgage Servicing Exam Procedures

On January 18, 2023, the Consumer Financial Protection Bureau (CFPB) released an updated version of its Mortgage Servicing Examination Manual. As the CFPB described in a corresponding blog post, the manual outlines “the types...more

Consumer Advocate Appointed New Director of Justice Department’s U.S. Trustee Program

The Director of the Justice Department’s U.S. Trustee Program (USTP), which oversees the administration of bankruptcy cases, is about to change for the first time in nearly 20 years. Clifford White will be stepping down from...more

FHA Extends Partial Waiver of Face-to-Face Meeting Requirement

On December 19, 2022, the Federal Housing Administration (FHA) issued an additional extension of the temporary waiver of face-to-face contact required under 24 CFR § 203.604 Contact with the Mortgagor, under Mortgagee Actions...more

We Wish You a Happy Thanksgiving as We Count Our Blessings

As we all hit the grocery store for that forgotten cranberry sauce and send a few last urgent work emails, we hope everyone is able to be with friends and family this Thanksgiving. Here at Bradley, we are counting our...more

Fifth Circuit Court of Appeals Invalidates Small-Dollar Rule, Throws the Future of the CFPB Into Question

On October 19, 2022, the Fifth Circuit Court of Appeals issued its opinion in Community Financial Services Association of America, et al. v. CFPB (CFSA v. CFPB) invalidating the CFPB’s Payday, Vehicle-Title, and Certain...more

Have You Heard of ADCONs? How to Get Ready for Fannie Mae and Freddie Mac’s New Address Confidentiality Program Requirements

In July of this year, Fannie Mae announced an update to the Agency’s Seller and Servicer Guidelines to include requirements that mortgage loan sellers and servicers comply with state address confidentiality programs (ADCONs),...more

Fannie Mae and Freddie Mac Direct Collection of Borrower Information to Further Fair Lending and Fair Servicing Aims

Two recent announcements by the Federal Housing Finance Agency (FHFA) will push the mortgage servicing industry to increase its collection and maintenance of consumer demographic and language preference data. On May 3,...more

CFPB, DOJ File Complaint Against Non-Bank Mortgage Lender for Deliberate Discrimination Against Minority Families

On July 27, 2022, the Consumer Financial Protection Bureau (CFPB) and the United States Department of Justice (DOJ) filed a complaint in the United States District Court for the Eastern District of Pennsylvania against...more

CFPB Issues Advisory Opinion Clarifying Its Views on When Debt Collectors Can Charge Consumers “Convenience Fees”

The Consumer Financial Protection Bureau (CFPB) issued an advisory opinion on June 29, 2022, clarifying its view as to the legality under the Fair Debt Collection Practices Act (FDCPA) of “convenience fees” for optional...more

CFPB Director Addresses the Final Report of the Interagency Task Force on Property Appraisal and Valuation Equity

The current leadership of the CFPB has not been shy about highlighting the importance of fair lending—and it is becoming increasingly clear that fair lending and equity within the financial services industry is one of the...more

CFPB Fall Supervisory Highlights Shed Light on Agency Priorities – Mortgage Servicing Loss Mitigation Violations

The COVID-19 pandemic has been a focal point for the Consumer Financial Protection Bureau (CFPB) – especially with regard to mortgage servicers and loss mitigation programs. In its Fall Supervisory Highlights, the CFPB noted...more

Servicers That Fail to Prepare, Prepare to Fail, Warns NY AG

In a December 13, 2021 letter to servicers, New York Attorney General Letitia James reminded servicers of their continuing obligations to assist New Yorkers amidst the pandemic and warned of enforcement actions against...more

After (Another) Unusual Year, We’re Very Thankful and Wish You a Happy Thanksgiving

Now that the pandemic’s “social distancing” is lessening, we hope you are all able to gather with friends and family this Thanksgiving. As we do the same, we wanted to count our blessings as we review the year. This year, we...more

Agencies’ Joint Statement on Supervisory and Enforcement Practices Forecasts Increased Scrutiny and Regulatory Activity

On November 10, 2021, the Board of Governors of the Federal Reserve, the Consumer Financial Protection Bureau, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller...more

New York Adds ADA-Type Requirement and Teeth to Debt Collection Procedure Act

On October 8, the governor of New York signed Bill No. AO-2260A to assist borrowers who need accommodation for visual impairments. Bill No. AO-2260A is “an act to amend the general business law, in relation to requiring debt...more

September Update: COVID-19 Mortgage Servicing Trends Report

Bradley is proud to share the following information collected from the live polls presented at its weekly COVID-19 Compliance Roundtables. The polling covers hot topics, including forbearances, deferrals, HUD loss mitigation...more

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