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Financial Services Report, Winter 2016

EDITOR’S NOTE - Hope you survived all of those awkward Thanksgiving holiday conversations— amazing how divided people are on whether the court got it right in the PHH case, isn’t it? So on we go into the holiday season,...more

Financial Services Report, Spring 2016

Why another law firm newsletter? Over ten years ago, Will Stern answered that question in the first Editor’s Note of the first Financial Services Report. Some things have changed since then—we no longer print and mail paper...more

CFPB Publishes HMDA File Specifications for Data Collected in 2017 and 2018

On February 18, the Consumer Financial Protection Bureau (CFPB) and the Federal Financial Institutions Examination Council (FFIEC) published new “File Specifications” for data to be collected pursuant to the Home Mortgage...more

Big Data, Big Government – Big Trouble? A Hard Look at the Final HMDA Rule

If all goes according to plan, financial institutions will report over 250 million data points related to mortgage loan applications and originations in 2018. If the mortgage market returns to the high volumes seen in 2005,...more

HOLY HMDA! CFPB Finalizes Changes to Home Mortgage Disclosure Rule

On October 15, 2015, the CFPB released a final rule amending Regulation C, 12 C.F.R. part 1003, which implements the Home Mortgage Disclosure Act (HMDA). Like the August 2014 proposed rule, the final rule includes changes to...more

The CFPB 2015 Forecast: Continued Cloudiness, Thunderstorms Likely

This will be a busy year at the Consumer Financial Protection Bureau (CFPB), and that certainly means it will be a busy year for financial institutions as well. In addition to exercising its supervisory and enforcement...more

CFPB Proposal Would Make 'HMDites' Of Us All

On July 24, the Consumer Financial Protection Bureau published long-awaited proposed revisions to its Home Mortgage Disclosure Act rules. The 573-page proposed rule would make sweeping changes to Regulation C, which...more

Just When You Thought It Was Safe to Take a Summer Vacation: CFPB Proposes Extensive New HMDA Rules

Last Thursday, the Consumer Financial Protection Bureau (CFPB) published its long-awaited new proposed revisions to its Home Mortgage Disclosure Act (HMDA) rules. The 573-page proposed rules would make sweeping changes to...more

CFPB Fair Lending Guidance for Indirect Auto Lenders—It’s Not Just About Cars

Several weeks ago, the Consumer Financial Protection Bureau (“CFPB”) issued a fair lending guidance bulletin (“Bulletin”) directed at financial institutions that make indirect automobile loans. While the Bulletin thus far has...more

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