I was only 9 years old when Jan and Dean in 1963 released their hit song “Dead Man’s Curve.” I thought about this song when I read the Conference of State Bank Supervisors’ (“CSBS”) Proposed Regulatory Prudential Standards...more
12/31/2020
/ Consumer Financial Products ,
CSBS ,
FHFA ,
Financial Regulatory Reform ,
Financial Services Industry ,
Mortgage Servicers ,
Mortgages ,
Non-Bank Lenders ,
Prudential Standards ,
Regulatory Agenda ,
Regulatory Requirements
The implications of the 2020 election for structured finance are coming into focus. Informed by our discussions in Washington, we can anticipate the likely direction of federal policy over the next two years that will impact...more
12/9/2020
/ Biden Administration ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Financial Regulatory Reform ,
GSE ,
Infectious Diseases ,
Inter-Bank Offered Rates (IBORs) ,
Securities and Exchange Commission (SEC) ,
Securitization ,
Structured Finance ,
UK Brexit ,
Volcker Rule
Should US state nonbank mortgage servicers be subject to “safety and soundness” standards of the type imposed by federal law on insured depository institutions, even though the nonbanks do not solicit and hold customer funds...more
When the federal Consumer Financial Protection Bureau (“CFPB”) last summer issued its Advance Notice of Proposed Rule Making (“ANPR”) to revise the definition of a “Qualified Mortgage” (“QM”) under the Dodd-Frank Act’s...more
2/20/2020
/ Ability-to-Repay ,
Advanced Notice of Proposed Rulemaking (ANPRM) ,
Annual Percentage Rate (APR) ,
Assignees ,
ATR-QM ,
Borrowers ,
Consumer Financial Protection Bureau (CFPB) ,
Dodd-Frank ,
Financial Regulatory Reform ,
Financial Services Industry ,
GSE ,
HOEPA ,
Investor Protection ,
Loans ,
Mortgages ,
Qualified Mortgage Rule ,
Qualified Residential Mortgages (QRB) ,
Regulatory Oversight ,
Regulatory Requirements ,
Risk Retention ,
Rulemaking Process ,
Securitization ,
Threshold Requirements ,
Underwriting