Evolving State Supervision: Issues Arising from State Qualification Standards and 'SAFE' Act Licensing, and Coordination with the CFPB
What Happened? In May 2024, the Financial Stability Oversight Council (FSOC or Council) issued a Report on Nonbank Mortgage Servicing (the Report). The Report recognizes the strengths of nonbank mortgage companies (NMCs) and...more
What Happened? Following the release of the Financial Stability Oversight Council (FSOC) Report on Nonbank Mortgage Servicing, Ginnie Mae announced in APM 24-08 that certain large nonbank Ginnie Mae Issuers will now be...more
On May 10, the Financial Stability Oversight Council (FSOC) released a report analyzing the growing nonbank mortgage servicing sector. The report discussed the sector’s significant market share, strengths and vulnerabilities...more
A&B Abstract: On November 3, 2023 the Financial Stability Oversight Council (hereinafter “FSOC” or “Council”) unanimously approved final versions of: (1) the new Analytic Framework for Financial Stability Risk...more
A&B Abstract: On April 21, 2023 the Financial Stability Oversight Council (hereinafter “FSOC” or “Council”) issued for public comment (1) a proposed analytic framework setting forth FSOC’s approach to identifying,...more
A bipartisan group of U.S. senators sent a letter dated April 8, 2020 to U.S. Department of Treasury Secretary Steven Mnuchin, in his capacity as Chair of the Financial Stability Oversight Council (FSOC), urging prompt action...more
Raise your hand if you are an independent mortgage banker, a residential mortgage real estate investment trust (“mREIT”) or a nonbank investor in residential mortgage loans that would like to be subject to additional federal...more
On February 28, 2017, B. Dan Berger, President and Chief Executive Officer of the National Association of Federally-Insured Credit Unions (the “NAFCU“), urged regulatory relief for credit unions in a letter submitted to the...more
Regulatory Developments - FSOC Rescinds GE Capital's SIFI Designation - On June 29, the Financial Stability Oversight Council (FSOC) announced that it had voted unanimously to “rescind its determination that...more
As required by Section 112(b)(2) of the Dodd-Frank Act, the Financial Stability Oversight Council released its 2014 Annual Report, which included, among other things, recommendations to address the risks posed by nonbank...more