More about Marissa Blundell
Blog Posts by Marissa Blundell:
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CFPB Proposes Amendments to ECOA to Provide More Flexibility for Lenders
The Consumer Financial Protection Bureau (CFPB) has issued proposed changes to the Equal Credit Opportunity Act in order to provide lenders with additional flexibility when collecting consumer ethnicity and race information.
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Agencies Issue Revised Risk Retention Proposal and QRM Definition
by: Marissa BlundellOn August 28, 2013, the Federal Reserve Board, HUD, the FDIC, the FHFA, the OCC and the SEC (collectively, “the agencies”) revised the jointly proposed risk retention rule originally issued in 2011. The new proposal provides two alternative revised definitions for “qualified residential mortgage” (QRM). Comments regarding this new proposal are due October […]
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CFPB Issues Rule Establishing Supervisory Authority Over Certain Nonbank Covered Persons
by: Marissa Blundell On June 26, 2013, the Consumer Financial Protection Bureau (CFPB) issued a final procedural rule which applies to its exercise of supervisory authority over certain nonbank covered persons based on risk determination. The rules govern the process through which the CFPB will determine whether it has reasonable cause to decide whether a […]
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CFPB Issues Clarification of Escrows Rule
by: Marissa Aquila Blundell, Esq.On May 16, 2013, the Consumer Financial Protection Bureau (CFPB) published clarifying and technical amendments to its Escrow Requirements under the Truth in Lending Act (Escrows Rule) which takes effect on June 1, 2013. With this amendment, the CFPB addresses a problem inadvertently created when it removed language applying ability-to-repay requirements […]
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Massachusetts Division of Banks Revises Examination Procedures
by: Marissa Aquila Blundell, Esq.On April 1, 2013, the Massachusetts Division of Banks (DOB) began to utilize revised examination procedures as part of its non-depository supervision program. The DOB has aligned its examination process with the procedures the Consumer Financial Protection Bureau (CFPB) uses to determine compliance with federal regulations during the mortgage origination process. […]
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CFPB Publishes TILA Escrow Compliance Guide for Small Entities
by: Marissa Aquila Blundell, Esq.On April 18, 2013, the Consumer Financial Protection Bureau (CFPB) published a TILA Escrow Compliance Guide for Small Entities, the latest in a series of implementation guides designed to help small creditors comply with new regulations issued in accordance with the Dodd-Frank Wall Street Reform and Consumer Financial Protection Act. […]
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Key Points to Loan Originator Compensation Requirements
by: Marissa Aquila Blundell, Esq.Last month the Consumer Financial Protection Bureau (CFPB) released final versions of several rules in accordance with Title XIV of Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank). Most of the new rules take effect in January of 2014, a short implementation period given the breadth and depth of the […]
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CFPB Issues Final Rule Containing HOEPA Changes
by: Marissa Aquila Blundell, Esq. On January 10, 2013, the Consumer Financial Protection Bureau (CFPB) published the final version of a rule broadening and strengthening the Home Ownership and Equity Protections Act (HOEPA), as required by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank). Specifically, one year from now on January 10, 2014, […]
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CFPB Issues Rule to Protect Consumers from Irresponsible Mortgage Lending
by: Anna DeSimoneJanuary 10, 2013 the Consumer Financial Protection Bureau (CFPB) adopted a new rule that will protect consumers from irresponsible mortgage lending by requiring lenders to ensure prospective buyers have the ability to repay their mortgage. The rule also protects borrowers from risky lending practices such as “no doc” and “interest only” features. […]
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Consumer Financial Protection Bureau Issues Ability-to-Repay and Qualified Mortgage Final Rule
by: Marissa Aquila Blundell, Esq.On January 10, 2013, the Consumer Financial Protection Bureau (CFPB) issued the final version of the hotly debated Ability- to-Repay rule set out in the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd Frank). The rule requires creditors to make a reasonable and good faith determination that borrowers have a […]