On June 6, 2024 federal regulators published a final rule addressing Quality Control Standards for Automated Valuation Models. This was a collaborative rulemaking effort that included regulators from the Office of the...more
Pursuant to section 1473(q) of the Dodd-Frank Act, a group of federal agencies have proposed a quality control rule for automated valuation models (AVMs). The agencies are the Comptroller of the Currency, Consumer Financial...more
Stemming from the Federal Housing Finance Agency’s (FHFA) 2019 validation and approval of credit score models final rule, the FHFA announced in October 2022 that Fannie Mae and Freddie Mac, the government-sponsored...more
Recently, the FHFA issued a request for input (RFI) on a single-family pricing framework for Fannie Mae and Freddie Mac (GSEs), including feedback on policy priorities and goals that FHFA should pursue in its oversight of the...more
On January 12, FHFA released an advisory bulletin communicating supervisory expectations for Fannie Mae and Freddie Mac (the Enterprises) related to the valuation of mortgage servicing rights (MSRs) for managing counterparty...more
On December 22, GSEs Fannie Mae and Freddie Mac announced replacement indices based on the Secured Overnight Financing Rate (SOFR) for their legacy LIBOR indexed loans and securities ...more
As fears of a recession grow, it would be prudent for everyone—servicers and regulators alike—to think hard about default servicing improvements and reforms. More than two years after the COVID-19 pandemic took hold of the...more
At the close of this month, certain moratoria on foreclosures and evictions are set to lift. While prior deadlines have been extended, it remains to be seen whether another continuance will be granted amidst an increase in...more
On July 7, 2021, Fannie Mae and Freddie Mac (the GSEs) introduced new uniform instruments (notes, security instruments, and riders) for use with loans to make them eligible for purchase by the GSEs. ...more
On April 27, the Bureau of Consumer Financial Protection (CFPB) issued a final rule to delay the mandatory compliance date for the General QM Final Rule until October 1, 2022. The CFPB stated that it issued the rule “to help...more
On April 27, the CFPB published a final rule extending the date for mandatory compliance with the new “general” Qualified Mortgage (QM) rule (General QM Rule) until October 1, 2022. In December, 2020, the CFPB published the...more
We previously reported on recent mortgage rulemakings that were finalized by the Consumer Financial Protection Bureau (CFPB or Bureau) late last year. Of the two final rules from the Bureau, one drastically simplifies the...more
As part of President Joe Biden’s efforts to address the continuing impact of the COVID-19 pandemic on American families, on February 16, the US Department of Housing and Urban Development, US Department of Veterans Affairs,...more
The Consumer Financial Protection Bureau (“CFPB”) recently issued two final rules aimed at bolstering the Qualified Mortgage (“QMs”) market. The first final rule amends the general eligibility category of QMs (“General QMs”)...more
The Consumer Financial Protection Bureau (“CFPB”) issued two relatively welcome surprises yesterday. First, along with ditching a debt-to-income ratio (“DTI”) ceiling, the agency expanded its proposed general Qualified...more
With mortgage delinquencies nearly doubling during the pandemic and serious delinquencies (mortgages more than 90 days past due) increasing to levels not seen since 2008, the Second Circuit offered some reprieve to Government...more
In mid May 2020, we highlighted that the Fannie Mae and Freddie Mac (GSEs) COVID-19 payment deferral programs put mortgage servicers at risk of violating some of the Consumer Financial Protection Bureau’s (CFPB) Mortgage...more
The CARES Act provided historic, temporary relief to mortgage holders facing Covid-19-related financial troubles. R. Aaron Chastain, partner at Bradley Arant Boult Cummings LLP, looks at where mortgage lenders and servicers...more
The Consumer Financial Protection Bureau (CFPB) recently proposed certain amendments to the General Qualified Mortgage (QM) definition in Regulation Z and issued a filing rule extending the expiration of the...more
The Consumer Financial Protection Bureau (CFPB or Bureau) on October 20 issued a final rule to extend the government-sponsored enterprises patch (GSE Patch), i.e., the “temporary qualified mortgage” exemption within the...more
A recent report from the US Commodity Futures Trading Commission encourages financial regulators to consider the risks climate change poses to the US financial system and includes recommendations for addressing these risks....more
Bradley is proud to share the following information collected from the live polls presented at its weekly COVID-19 Compliance Roundtables. This report is intended to show industry trends, not facts, and does not necessarily...more
The Federal Housing Finance Agency (FHFA) announced on August 27 that Fannie Mae and Freddie Mac (the GSEs) will extend their moratorium on foreclosures and evictions until at least December 31, 2020. The foreclosure...more
The Consumer Financial Protection Bureau (CFPB or Bureau) issued a proposed rule on August 18 to create a new category of seasoned qualified mortgages (Seasoned QMs) that, if finalized as written, would carry significant...more