More about Marissa Blundell
Blog Posts by Marissa Blundell:
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Justice Department and CFPB Form Mutual Fair Lending Agreement
by: Marissa Aquila Blundell, Esq. On December 6, 2012, the United States Department of Justice (DOJ) and the Consumer Financial Protection Bureau (CFPB) executed a Memorandum of Understanding (MOU) Regarding Fair Lending Coordination. The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank), authorized the CFPB to implement and enforce consumer financial law, including but not […]
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CFPB and Fed Increase Reg Z Dollar Threshold
by: Marissa Aquila Blundell, Esq. On November 20, 2012, the Consumer Financial Protection Bureau (CFPB), jointly with the Federal Reserve Board (FRB) where applicable, issued three final rules which adjust certain monetary thresholds in the Truth-in-Lending Act’s (TILA) Regulation Z and Consumer Leasing Act’s (CLA) Regulation M. The Dodd-Frank Wall Street Reform and Consumer […]
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CFPB Delays Effective Date for Dodd-Frank
by: Marissa Aquila Blundell, Esq.On Friday, November 16, 2012, the Consumer Financial Protection Bureau (CFPB) published a final rule which delays the effective date for compliance with the new mortgage disclosure rules included in Title XIV of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank). The CFPB’s rule provides an exemption from compliance with […]
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MERS Annual Compliance Requirements
Special Announcement MERS Annual Quality Assurance Standards Compliance Report Summary of Requirements 1. All residential mortgage lenders who are registered MERS Members are required to comply with the MERS Quality Assurance Requirements. 2. Each Member must submit a Quality Assurance Plan by December 31, 2012 utilizing the proper template provided by MERSCORP […]
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Update on CFPB Proposed LO Compensation Rule
by Marissa Aquila Blundell, Esq.Sr. VP & General CounselIndustry comments regarding the Consumer Financial Protection Bureau’s proposed rules governing loan originator compensation, implementing key provision of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) must be submitted by October 16, 2012. Although the CFPB extended the comment period for a limited section of […]
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Massachusetts Passes Act to Prevent Unlawful and Unnecessary Foreclosures
by Marissa Aquila Blundell, Esq.Sr. VP & General Counsel The Massachusetts legislature recently approved an Act to Prevent Unlawful and Unnecessary Foreclosures, which Governor Patrick is expected to sign in the next few days. Major provisions in the bill will be effective immediately upon its being signed and will impact the Massachusetts foreclosure process significantly. […]
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CFPB Considers Proposals Affecting Originator Compensation and Qualification
by Marissa Aquila Blundell, Esq.Sr. VP & General Counsel The Consumer Financial Protection Bureau (CFPB) has begun to publish press releases highlighting policies under consideration in advance of its issuing proposed rules. Based on the timelines mentioned by the CFPB in these press releases, it appears that the industry should expect the rule-making process, consisting of […]
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CFPB Addresses Payments to Loan Originators’ Qualified Plans
by Marissa Aquila Blundell, Esq. Senior Vice President & General Counsel On April 2, 2012, the Consumer Financial Protection Bureau (CFPB) issued Bulletin 2012-02, which presents guidance regarding loan originator compensation and qualified profit sharing. The specific question covered is whether and how the current loan originator compensation restrictions affect employer contributions to qualified profit sharing, […]
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Consumer Financial Protection Bureau Finalizes Mortgage Origination Examination Procedures
by Marissa Aquila Blundell, Esq.Senior Vice President & General Counsel On January 11, 2012, the CFPB updated its Supervision and Examination Manual to include its Mortgage Origination Examination Procedures. Previously, the CFPB released its general examination procedures for large depository institutions and non-bank financial services providers which stressed the importance of an effective compliance management […]
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OCC Interim Final Rule republishing OTS Regulations: Highlights of Provisions related to Savings Associations’ Mortgage Lending Activities
By Marissa Aquila Blundell, Esq.Vice President & Senior Counselmarissa@bankersadvisory.com On August 9, 2011, the Federal Register published the Office of the Comptroller of the Currency (OCC) interim final rule republishing certain Office of Thrift Supervision (OTS) regulations. This rule is one in a series of interim final rules being issued on the heels of the […]