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Consumer Financial Services 2023 Year in Review and A Look Ahead

We are pleased to share our annual review of regulatory and legal developments in the consumer financial services industry. With active federal and state legislatures, consumer financial services providers faced a challenging...more

CFPB Highlights Extension of Period to Request Initial COVID-19 Hardship Forbearance for Certain Government Backed Loans

On October 4, the Consumer Financial Protection Bureau (CFPB) announced on its website that the deadline to request initial forbearance for a COVID-19 hardship for loans backed by the Federal Housing Administration (HUD/FHA),...more

CFPB Issues Interpretive Rule on Juneteenth and Mortgage Disclosure Requirements

On June 17, the president signed legislation designating “Juneteenth National Independence Day, June 19” as a federal holiday. Because the legislation took effect immediately, it raised compliance questions for residential...more

CFPB Issues the 2021 Mortgage Servicing COVID-19 Rule

On June 28, the Consumer Financial Protection Bureau (CFPB) issued a final rule to amend Regulation Z’s mortgage servicing requirements in order to “establish temporary special safeguards to help ensure that borrowers have...more

Florida Supreme Court Quashes Third District Holding: Note Supersedes Mortgage if Conflict Arises

In WVMF Funding v. Palmero, the Supreme Court of Florida quashed the Third District Court of Appeals’ holding in OneWest Bank, FSB v. Palmero, 283 So. 3d 346 (Fla. 3d DCA 2019) that Mrs. Palmero was a “borrower” under a...more

CFPB Issues Rule Delaying the Mandatory Compliance Date of the New General Qualified Mortgage Final Rule

On April 27, the Bureau of Consumer Financial Protection (CFPB) issued a final rule to delay the mandatory compliance date for the General QM Final Rule until October 1, 2022. The CFPB stated that it issued the rule “to help...more

CFPB Takes Actions to Limit COVID-19-Related Mortgage Foreclosures

On April 5, the Consumer Financial Protection Bureau (CFPB) issued a notice of proposed rulemaking (NPR) to amend Regulation Z, specifically to “prevent avoidable foreclosures” due to the COVID-19 pandemic “as the emergency...more

CFPB Proposes to Delay the Mandatory Compliance Date of the New General Qualified Mortgage Final Rule

On February 23, the Consumer Financial Protection Bureau (CFPB) issued a statement that it planned to propose a rule to “delay the July 1, 2021 mandatory compliance date of the General QM Final Rule.” Consistent with that,...more

The CFPB Revises Reg. Z’s Qualified Mortgage Loan Criteria in Anticipation of the GSE Patch’s Expiration

In anticipation of the “GSE patch” expiring, the Consumer Financial Protection Bureau (“CFPB”) issued several final rules in 2020 to amend Regulation Z (“Reg. Z”). Concerns have existed that the expiration of the GSE patch...more

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