Archive

On September 13 the Consumer Financial Protection Bureau published it latest revisions to final rules that were published last January. The 274-page final rule: Revises error resolution procedures and information requests (§§ 1024.35 and 1024.36), and loss mitigation (§ 1024.41). With respect to loss mitigation, two of the revisions concern the requirement in § 1024.41(b)(2)(i) that a servicer review a borrower’s loss mitigation application within five days and provide a notice to the borrower acknowledging […]

On August 28 the Board of Governors of the Federal Reserve System, the Department of Housing and Urban Development, the Federal Deposit Insurance Corporation, the Federal Housing Finance Agency, the Office of the Comptroller of the Currency, and the Securities and Exchange Commission issued a notice revising a proposed rule requiring sponsors of securitization transactions to retain risk in those transactions. The new proposal revises a proposed rule the agencies issued in 2011 to implement […]

In the past few weeks the Consumer Financial Protection Bureau (CFPB) put in place over 3,500 pages of new regulations to implement various provisions of the Dodd-Frank Act. Or, maybe they didn’t. Yesterday the D.C. Circuit of the Federal Court of Appeals issued a ruling that the President can make recess appointments only when the Senate has formally adjourned between sessions of Congress. If the ruling stands, various appointments, including President Obama’s recess appointment of […]

On Sunday January 20, 2013 the Consumer Financial Protection Bureau (CFPB) published a final rule amending Regulation Z to revise and clarify existing regulations and commentary on loan originator compensation. The rules also implement Dodd-Frank Act provisions that prohibit certain arbitration agreements and the financing of certain credit insurance in connection with a mortgage loan. The 540-page final rule was published just hours before the Dodd-Frank mandated January 21, 2013 deadline. The rules take effect […]

On January 18, 2013 the Consumer Financial Protection Bureau published a124-page final rule to amend Regulation B, which implements the Equal Credit Opportunity Act. The final rule revises rules for appraisals and other valuations that was enacted as part of the Dodd-Frank Act. The final rule is effective on January 18, 2014. For applications for credit secured by a first lien on a dwelling the new rule: Requires creditors to notify applicants within three business […]