A&B ABstract: On April 1, 2021, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) issued a Compliance Bulletin and Policy Guidance (the “Bulletin”) on the Bureau’s supervision and enforcement priorities with...more
A&B Abstract: The Conference of State Bank Supervisors (“CSBS”) proposed regulatory prudential standards (the “Standards”) to develop a consistent regulatory structure of nonbank mortgage servicers. Comments on all aspects...more
A&B Abstract: On September 25, California Governor Gavin Newsom signed into law Senate Bill 908, which, in part, enacts the California Debt Collection Licensing Act (“Act”). ...more
A&B ABstract: Maryland’s Governor has issued an Executive Order providing that until the COVID-19 state of emergency is terminated: (1) foreclosure sales will only be valid if the servicer had notified the borrower of their...more
A&B ABstract: On October 7, 2020, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) rescinded Compliance Bulletin 2015-05, RESPA Compliance and Marketing Services Agreements (“Bulletin 2015-05”). In addition, the...more
A&B ABstract: On September 1, 2020, the Deputy Superintendent of the New York Department of Financial Services (“NYDFS”), issued guidance (the “Guidance”) to New York State regulated mortgage lenders and servicers...more
A&B ABstract: The FTC is seeking public comment on proposed changes to five FCRA rules aimed at clarifying that these rules, as promulgated by the FTC, apply only to motor vehicle dealers, as equivalent rules promulgated by...more
A&B Abstract: On July 16, 2020, the U.S. House Committee on Financial Services’ (the “Committee”) Subcommittee on Oversight and Investigations (the “Subcommittee”) held a hearing to discuss mortgage servicers and their...more
A&B Abstract: On June 30, 2020, Delaware Governor, John Carney, issued a Twenty-Third Modification (the “Order”) to the Declaration of a State of Emergency (the “State of Emergency”), initially issued on March 12, 2020. The...more
A&B ABstract - On June 17, 2020, New York Governor Andrew Cuomo signed into law two measures, effective immediately, providing for mortgage forbearances for privately backed residential mortgage loans during the COVID-19...more
A&B ABstract: On May 15, the Office of the Comptroller of the Currency (“OCC”) issued a final rule, effective August 3, 2020, addressing the “valid-when-made” doctrine. ...more
A&B Abstract: On April 23, 2020, the attorneys general of 33 states, the District of Columbia and Puerto Rico (the “Attorneys General”) sent two letters, one to the Federal Housing Finance Agency (“FHFA”) and the other to the...more
A&B ABstract: On April 27, the FHFA provided clarification on the repayment of mortgage loan forbearance granted in response to the COVID-19 pandemic....more
A&B Abstract: On March 24, 2020, Delaware Governor, John Carney, issued a Sixth Modification (the “Order”) to the Declaration of a State of Emergency (the “State of Emergency”) initially issued on March 12, 2020. ...more
A&B Abstract: On April 20, 2020, Massachusetts Governor, Charlie Baker, signed into law HB 4647 (2020 Mass. Acts 65), an emergency measure, effective immediately, providing for mortgage forbearances and a moratorium on...more
A&B ABstract:
In response to COVID-19, on Friday March 28, 2020, President Trump signed into law the “Coronavirus Aid, Relief, and Economic Security Act” (the “CARES Act”). This is a monumental $2 trillion stimulus...more
3/31/2020
/ Banking Sector ,
Banks ,
CARES Act ,
Coronavirus/COVID-19 ,
Credit Reports ,
Eviction ,
Fair Credit Reporting Act (FCRA) ,
Financial Services Industry ,
Financial Stimulus ,
Forbearance Agreements ,
Foreclosure ,
Moratorium ,
Mortgage Lenders ,
Relief Measures
The Coronavirus Aid, Relief, and Economic Security (CARES) Act sprawls across 800 pages. Our Financial Services & Products Group delves into the sections that deal specifically with banking and lending....more
3/31/2020
/ Banking Sector ,
Banks ,
CARES Act ,
Coronavirus/COVID-19 ,
FDIC ,
Federal Loans ,
Financial Institutions ,
Financial Services Industry ,
Financial Stimulus ,
Relief Measures ,
SBA ,
SBA Lending Programs ,
Small Business
On March 19, New York Governor Mario Cuomo issued Executive Order No. 202.7, “Continuing Temporary Suspension and Modification of Laws Relating to the Disaster Emergency” (the “Order”)....more
A&B ABstract:
The Winter 2020 Supervisory Highlights identifies the CFPB’s findings from recent examinations, noting violations that resulted in compliance management system weakness....more
A&B ABstract:
The Consumer Financial Protection Bureau (“CFPB” or the “Bureau”) issued a Policy Statement to provide a framework for how it intends to apply the Dodd-Frank Act’s “abusiveness” standard going forward in its...more
A&B ABstract - In keeping with broader scrutiny on non-bank servicers, the Federal Housing Finance Agency (FHFA) is proposing new financial eligibility requirement for non-bank servicers doing business with Fannie Mae or...more
A&B Abstract:
On January 27, 2020, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) published a policy statement announcing a new designation for CFPB guidance, known as “Compliance Aids,” and explaining the...more
New York’s amended mortgage loan servicer regulations are a substantial departure from previous versions and could go beyond federal rules. Our Financial Services & Products Group delves into technicalities and ramifications...more
A&B ABstract: Effective March 5, 2020, New York Assembly Bill 5626 (“AB 5626”) regulates the origination and servicing of the federal U.S. Department of Housing and Urban Development (“HUD”) home equity conversion mortgages...more
The New York Department of Financial Services (“NYDFS”) has issued final mortgage servicer business conduct rules found in Part 419 of the Superintendent’s Regulations....more