CFPB
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Consumer Financial Protection Bureau Proposes Loan Servicing Rules
by Anna DeSimonePresident On August 9, 2012 the Consumer Financial Protection Bureau (CFPB) today proposed two notices containing rules concerning mortgage servicing. The Dodd-Frank Wall Street Reform and Consumer Protection Act addresses some of these problems and imposes certain requirements on servicers, which the CFPB is implementing and refining. The new rules will be finalized […]
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CFPB Issues its First Enforcement Action against Capital One Bank
by Donna M. Saati, Esq.Associate Counsel In its first public enforcement action since its inception, the Consumer Financial Protection Bureau (the “CFPB” or “Bureau”), has ordered Capital One Bank, (U.S.A) N.A. (“Capital One”) to refund consumers and pay civil money fines to settle charges of deceptive marketing tactics. The CFPB, established by the Dodd-Frank Act […]
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CFPB and Prudential Regulators Issue Joint Guidance on Loan Servicing Practices
by Anna DeSimone President and Founder Guidance Highlights Protections for Military Homeowners On June 21, 2012 the Consumer Financial Protection Bureau (CFPB) along with the following prudential regulators: the Board of Governors of the Federal Reserve System; the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of […]
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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 to Pursue Discriminatory Lenders
by Anna DeSimonePresident & Founder On April 18, 2012, the Consumer Financial Protection Bureau (CFPB) issued Bulletin 2012 -04 to provide guidance regarding compliance with the fair lending requirements of the Equal Credit Opportunity Act (ECOA). The CFPB stated it will use all available legal avenues, including disparate impact, to pursue lenders whose practices discriminate […]
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CFPB Proposes New Mortgage Servicing Rules
by Anna De SimonePresident & Founder On April 9, 2012 the Consumer Financial Protection Bureau (CFPB) released an outline of rules under consideration to help protect mortgage borrowers from being hit by costly surprises or getting the runaround from their mortgage servicer. The CFPB plans to formally propose rules this summer and finalize them in […]
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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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CFPB Rule for Alternative Mortgage Transaction Parity Act
by Marissa Aquila Blundell, Esq. Senior Counsel & Vice Presidentmarissa@bankersadvisory.com On July 22, 2011, the Consumer Financial Protection Bureau (CFPB) issued an interim final rule which preserved the ability of state housing creditors to make alternative mortgage transactions notwithstanding state law prohibitions. However, the rule incorporates amendments to the Alternative Mortgage Transaction Parity Act (AMTPA), required […]
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Dodd Frank Issues Rule on Adverse Action Notices
by Marissa Aquila Blundell, Esq. Senior Counsel & Vice Presidentmarissa@bankersadvisory.com The Federal Reserve Board (FRB) and Federal Trade Commission (FTC) issued a final rule on July 6, 2011 requiring creditors to provide additional information in adverse action notices if a credit score is used in making the credit decision. The new rule is effective 30 days […]