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
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
Ginnie Mae’s newly imposed restriction on repooling of reperforming forborne loans yet again penalizes servicers acting as essential service providers in the continuing efforts to protect mortgagors facing financial hardship...more
In a new era of double-digit unemployment resulting from the COVID-19 pandemic, it may be tough for a mortgage lender to predict the amount and stability of someone’s income in order to determine qualification for a home...more
6/10/2020
/ Ability-to-Repay ,
Borrowers ,
Consumer Financial Products ,
Coronavirus/COVID-19 ,
Fannie Mae ,
Financial Services Industry ,
Freddie Mac ,
Freelance Workers ,
GSE ,
Independent Contractors ,
Mortgage Loan Servicing Standards ,
Mortgages ,
Qualifying Income ,
Underwriting
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
It is widely anticipated that the London Interbank Offered Rate (“LIBOR”) will be discontinued in 2021. As LIBOR commonly is used as an index rate for both residential mortgage and consumer loans, its discontinuance has the...more
1/30/2020
/ Adjustable Rate Financial Products ,
Adjustable-Rate Mortgage ,
Alternative Reference Rates Committee (ARRC) ,
Consumer Financial Products ,
Consumer Lenders ,
Consumer Loan Companies ,
Financial Services Industry ,
Interest Rates ,
Libor ,
Loans ,
Mortgages ,
NYDFS ,
Regulatory Oversight ,
Secured Overnight Funding Rate (SOFR) ,
Transitional Arrangements