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Mulvaney confirms CFPB PII breaches
Posted Date: Monday, January 22, 2018
In a letter responding to inquiries from Sen. Elizabeth Warren (D-Mass.) on steps taken to ensure data security, Consumer Financial Protection Bureau acting director Mick Mulvaney confirmed hundreds of confirmed breaches of consumers’ personally identifiable information (PII), and hundreds more suspected breaches.
“I do not expect you, as an outside observer of the bureau’s activities, to be aware of the bureau’s other data security risks,” Mulvaney wrote to Warren.
Read on for more from Mulvaney's letter, including recent breaches in the Consumer Complaint Database dating to November.
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CFPB dismisses tribal payday lending case
Posted Date: Monday, January 22, 2018
Two days after the Consumer Financial Protection Bureau (CFPB) announced it would re-examine its small-dollar/payday lending rule, the bureau dropped a lawsuit it filed against four online tribal payday lenders.
The case against the Habematolel Pomo of Upper Lake (HPUL) Tribe Economic Development Arms – Golden Valley Lending, Inc., Silver Cloud Financial, Inc., Mountain Summit Financial, Inc., and Majestic Lake Financial, Inc. – was announced in April 2017.
Read on for reaction from HPUL Chairperson Sherry Treppa, counsel for the HPUL, and a statement from the CFPB on its decision to drop the case.
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Mulvaney announces RFI; regulation by enforcement could be a target
Posted Date: Thursday, January 18, 2018
In his first public pronouncement as acting director since the end of November, Mick Mulvaney announced the Consumer Financial Protection Bureau (CFPB) would begin issuing requests for information (RFIs) on nearly all aspects of the bureau’s work.
The first RFI will seek public comment on Civil Investigative Demands, but Hahn Loeser & Parks, LLP Partner Derek Diaz told RESPA News the most obvious area which could be targeted by public feedback is the CFPB’s practice of regulation by enforcement.
Read on for more of the CFPB’s announcement and Diaz’s ideas of how the process could unfold.
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Without president, Ginnie Mae gains authority
Posted Date: Thursday, January 18, 2018
As it approached one year since Ginnie Mae President Ted Tozer left the agency, the Department of Housing and Urban Development (HUD) moved to create a stable leadership framework as it awaits a replacement.
HUD Secretary Ben Carson published two rules in the Federal Register on Jan. 18 which delegated authority at Ginnie Mae to both the president and to the executive vice president/chief operations officer – who currently is acting president Michael Bright.
Read on to find more about the move and the succession line in the absence of a Senate-confirmed president.
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Actual damages properly pled in dual-tracking case
Posted Date: Thursday, January 18, 2018
A Maryland borrower whose home fell into default applied for a loan modification from her servicer, but her application was denied.
Before her appeal of the denial could be conducted, the servicer moved to foreclose on her property. The borrower sued for violation of RESPA’s dual-tracking standards and failure to respond to a qualified written request (QWR).
The district court in Maryland found the servicer had violated dual-tracking standards and failed to properly comply with the QWR, and then it examined actual damages to find the borrower demonstrated those as well. Read on for details of the case.
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Small-dollar lending rule to be reviewed
Posted Date: Thursday, January 18, 2018
On the effective date for the Consumer Financial Protection Bureau’s rule covering small-dollar lending, the bureau issued a statement that it intends to reopen rulemaking and accept waiver requests for entities considering applying to be a registered information system.
“The bureau intends to engage in a rulemaking process so that the bureau may reconsider the payday rule,” the CFPB said in its statement.
Read on for the reasons why the bureau is reviewing the rule and reaction from supporters and critics of the decision.
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NAFCU makes FAQ available on ADA issue
Posted Date: Thursday, January 18, 2018
In its continuing efforts to provide assistance for credit unions which have been served legal notices on compliance with the Americans with Disabilities Act, the National Association of Federally-Insured Credit Unions (NAFCU) announced it released a list of frequently asked questions on the subject for members and nonmembers.
The document explains why credit unions are being targeted with legal action and what NAFCU is doing to help, among other information, the association said in a statement on its website.
Read on for more about the issue and NAFCU’s guidance for the industry.
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Supreme Court to hear Lucia
Posted Date: Monday, January 15, 2018
After the Department of Justice (DOJ) changed its stance in Lucia v. SEC, a case which looked into the Securities and Exchange Commission’s procedure for appointing administrative law judges, the Supreme Court on Friday granted petitions for writs of certiorari.
At issue will be the question, “Whether administrative law judges of the Securities and Exchange Commission are Officers of the United States within the meaning of the Appointments Clause.”
Read on for more about the DOJ’s change of heart and how the potential implications of a ruling could affect the Consumer Financial Protection Bureau.
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Experts discuss next step as English files appeal
Posted Date: Monday, January 15, 2018
Late Wednesday District of Columbia District Judge Timothy J. Kelly issued his ruling on a temporary restraining order requested by Consumer Financial Protection Bureau Deputy Director Leandra English against President Donald Trump’s appointment of Mick Mulvaney as acting director.
Kelly, who earlier denied a temporary restraining order request by English, this time denied the preliminary injunction as well.
But does that end the CFPB leadership battle? RESPRO’s Ken Trepeta and attorney Richard Horn talked to RESPA News about the next steps.
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CFPB sticks to argument in enforcement lawsuit
Posted Date: Monday, January 15, 2018
In a California lawsuit, the Consumer Financial Protection Bureau (CFPB) recently filed a reply brief supporting its previously held position, which resulted in a nearly $8 million fine against the company.
Although the CFPB has chosen to alter its legal stance in an action involving a civil investigative demand request against Nexus Services, and reportedly was considering dropping an enforcement settlement with Wells Fargo, in this case the bureau stuck to its case and requested the court reject a motion for post-trial relief.
Read on for more about the bureau’s actions in its lawsuit against Nationwide Biweekly.
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FDIC looks at credit management information systems
Posted Date: Monday, January 15, 2018
In the Winter 2017 issue of the Federal Deposit Insurance Corp.’s (FDIC) Supervisory Insights, the agency takes a look into credit management information systems (MIS) and how they can be a part of a strong credit risk management program.
The report looked at MIS from 24 large state nonmember banks and found that their programs “did a good job tracking loan delinquencies, chargeoffs, and other measures of current loan portfolio performance,” which the FDIC called the lagging indicators of risk.
Read on to find out where the FDIC found room for improvement in the bank’s MIS programs.
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Nevada court examines RESPA compliance role in foreclosure
Posted Date: Monday, January 15, 2018
A Las Vegas man who fell behind on his mortgage payments was facing foreclosure on his property and filed a qualified written request (QWR) with his servicer.
The day his servicer responded, he also received notice of sale for the foreclosure sale of his property. The borrower sued, citing violations of RESPA for failure to comply in responding to his QWR and alleging his servicer secretly encouraged the lender to foreclose.
The district court found the borrower was able to sufficiently plead that his servicer failed to comply with RESPA. But did he sufficiently allege actual damages? Read on for the ruling.
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Former MBA staffer sworn in at HUD
Posted Date: Monday, January 15, 2018
Former Mortgage Bankers Association Associate Vice President of Legislative Affairs Len Wolfson was among four new leaders sworn in by Department of Housing and Urban Development (HUD) Secretary Ben Carson.
Wolfson will be HUD’s assistant secretary of congressional and intergovernmental relations, serving as the principal advisor to Carson, the deputy secretary and senior staff on legislative affairs, congressional relations, and policy matters affecting federal, state and local governments.
Read on for more on Wolfson and the other new leaders sworn in by Carson.
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Three tied to independent report leave Wells
Posted Date: Thursday, January 11, 2018
Wells Fargo confirmed the departure of three staffers who were directly or indirectly referenced in the report of the Independent Directors of the Board of Wells Fargo on their investigation of sales practices at the Community Bank.
Two of the three were directly mentioned in the independent directors report, which was conducted by a four-director Oversight Committee and assisted by independent counsel Shearman & Sterling LLP.
The third played a role in a section within the Law Department referenced in the report. Read on for more.
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Warren: Mulvaney put halt to all exam activity
Posted Date: Thursday, January 11, 2018
Citing emails from the Consumer Financial Protection Bureau (CFPB) to bureau examiners, Sen. Elizabeth Warren (D-Mass.) wrote to CFPB leadership requesting information on a freeze on examiner information issued by Mick Mulvaney.
The freeze, Warren claims, has halted examination work by the bureau.
Read on for more from Sen. Warren’s letter, including her claim that Mulvaney’s actions were aimed at “hobbling the agency.”
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Citi fined over BSA compliance
Posted Date: Thursday, January 11, 2018
Citibank has been handed a $70 million civil money penalty by the Office of the Comptroller of the Currency (OCC) for failing to comply with a 2012 consent order concerning deficiencies with Bank Secrecy Act (BSA) and anti-money laundering (AML) compliance.
Citi consented to the order, issued Dec. 27, 2017, and announced Jan. 4.
Citi neither admitted to nor denied the charges from the OCC. Read on for more about the office’s enforcement action.
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HUD OIG looks back in report to Congress
Posted Date: Thursday, January 11, 2018
The Department of Housing and Urban Development (HUD) Office of the Inspector General (OIG) recently released its semiannual report to Congress, detailing the work the OIG did in the second half of fiscal 2017.
“This report describes the remarkable accomplishments of the dedicated employees of HUD OIG,” acting Inspector General Helen Albert wrote. “Among these are a continuation of OIG’s return on investment, which for fiscal year 2017 is 37 to 1 for every dollar spent on our work.”
Read on for more highlights from the report, including audits in HUD’s single-family housing unit.
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Davis Malm forms dedicated banking and credit practice
Posted Date: Wednesday, January 10, 2018
Boston law firm Davis, Malm & D’Agostine, P.C. announces that it has established a dedicated, multidisciplinary Banking and Credit Practice to better meet the needs of lenders and borrowers in today’s capital marketplace.
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Treliant welcomes Ellen Rose as director
Posted Date: Wednesday, January 10, 2018
Ellen Rose, a leader in commercial and residential mortgage banking and servicing with a career spanning 30 years, has joined Treliant Risk Advisors as a director.
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Was English unjustly hired at CFPB?
Posted Date: Monday, January 8, 2018
Sen. Ron Johnson (R-Wis.) has written to the Office of Special Counsel to look into the hiring of Leandra English at the Consumer Financial Protection Bureau (CFPB).
Johnson said in a letter to the office that the Office of Personnel Management hastily approved” English’s conversion from a political appointee to a career position with the CFPB and that this might have been done outside of competitive hiring practices.
That conversion, also known as burrowing, “threatens to undermine the merit-based principals” of civil service, Johnson wrote. Read on for more.
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Appellate court: Surcharge rule violates First Amendment
Posted Date: Monday, January 8, 2018
In a California case over the ability of retailers to charge a surcharge for credit card transactions, the Ninth Circuit Court of Appeals reviewed a district court ruling which granted summary judgment for the retailer plaintiffs against a state statute.
The question arose whether the statute infringed on the First Amendment rights of the retailers to promote a higher price for credit-card transactions as a surcharge.
The appellate court ruled that the retailers had standing, and that the challenge to the First Amendment was as-applied rather than facial, and upheld the district court’s ruling.
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House staffer takes English’s old job
Posted Date: Monday, January 8, 2018
House Financial Services Committee Chairman Jeb Hensarling (R-Texas) announced that the new chief of staff at the Consumer Financial Protection Bureau will be a former member of the House committee staff.
The former chief of staff was Leandra English, who was promoted to deputy director the day that former Director Richard Cordray announced his resignation.
Read on for more details about the new hire, and who will become the new staff director at the House committee.
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HUD delays fair housing rule
Posted Date: Monday, January 8, 2018
A 2015 Department of Housing and Urban Development (HUD) rule designed to assist in meeting statutory fair housing obligations has been delayed for a year, HUD announced in a proposed rule published in the Federal Register.
In reviewing initial assessments required by the new rule, HUD said the industry required more time to comply.
The move was met with swift opposition from critics of the administration. Read on for more about the delay and reaction.
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Trades back AML bill
Posted Date: Monday, January 8, 2018
Twelve trade associations recently wrote to the House Financial Services Committee to express their support for the Counter Terrorism and Illicit Finance Act introduced by Reps. Steven Pearce (R-N.M.) and Blaine Luetkemeyer (R-Mo.).
The letter said the associations believe the bill will modernize anti-money laundering (AML) and help prevent the use of shell companies to launder money.
Read on for more about how the bill addresses industry concerns over the disclosure of ownership.
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Brown ties PHH settlement to CFPB stance
Posted Date: Monday, January 8, 2018
Sen. Sherrod Brown (D-Ohio), the ranking member on the Senate Banking Committee, has urged the president to stand behind the Consumer Financial Protection Bureau in its case against PHH Corp.
Brown, who filed an amicus brief in PHH Corp. v. CFPB along with Rep. Maxine Waters (D-Calif.) and other legislators, made the appeal following the news of PHH’s $45 million settlement over allegations of mortgage servicing violations by state attorney generals.
Read on for more about the senator’s call to action for the administration.
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Regulators caution Texans on home-equity lending
Posted Date: Thursday, January 4, 2018
The passage of an amendment to the Texas Constitution in November by voters has state regulatory authorities cautioning lenders against making home-equity loans for the first 12 days of 2018.
Proposition 2, which was passed by state voters by a 69-31 margin, changed the amount of fees which are able to be charged for home-equity loans; expanded the amount of lenders able to make loans to subsidiaries of banks, savings and loans and credit unions; expanded refinancing abilities and the availability of draws on a line-of-credit home-equity loan and allowed borrowers with agricultural exemptions to access home-equity loans in certain circumstances.
Read on for more about why state regulators are cautioning lenders against originating home-equity loans at the start of the year.
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Industry push leads Justice Department to withdraw ADA ANPRMs
Posted Date: Thursday, January 4, 2018
Following recent advocacy from credit unions and financial institutions, the Justice Department rescinded four advanced notices of proposed rulemaking (ANPRM) related to the Americans with Disabilities Act.
The industry had petitioned to Justice Department to provide clearer guidance, specifically on ANPRMs related to the accessibility of web information.
A rash of lawsuits had been filed against credit unions and financial institutions since the publishing of the ANPRM in 2010. Read on for more about the Justice Department’s reasoning behind the withdrawals.
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CFPB adds HMDA compliance tools
Posted Date: Thursday, January 4, 2018
As the Consumer Financial Protection Bureau’s (CFPB) new rules covering the Home Mortgage Disclosure Act (HMDA) took effect Jan. 1, the bureau announced the release of tools designed to help lenders with compliance.
The CFPB said it had two new tools that will be available for lenders who are responsible for HMDA collection.
Read on to find out what the tools do and where they are available.
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PHH settles claims dating to 2012
Posted Date: Thursday, January 4, 2018
PHH Mortgage Corp. announced a settlement to allegations of improperly services loans from 2009-2012, saying the terms of the agreement largely match the company’s practices today.
“In fact, the servicing standards that we are required to adopt under the terms of the settlement are largely PHH’s servicing standards today,” PHH said.
The settlement with 49 state attorneys general, the District of Columbia and more than 45 state mortgage regulators will total $45 million, including more than $30 million in redress to borrowers.
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Ocwen settles with two more states
Posted Date: Thursday, January 4, 2018
As 2017 came to a close, Ocwen Financial Corp. inched closer toward completing settlements with state regulators.
Ocwen announced it reached agreement with two more states, Oregon and Wyoming, related to actions taken in April by mortgage and banking regulatory agencies from 30 states and the District of Columbia and two state attorneys general.
Read on for details of the agreements and reaction from Ocwen.
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Ballard Spahr and Lindquist & Vennum Have Merged
Posted Date: Tuesday, January 2, 2018
Ballard Spahr and Lindquist & Vennum have completed their merger, Ballard Spahr Chair Mark Stewart announced. The combined firm — which retains the name Ballard Spahr — has more than 650 lawyers in 15 offices across the United States.
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Premier ERISA Law Firm Expands its St. Louis Office
Posted Date: Tuesday, January 2, 2018
Marcia S. Wagner, the Managing Director of The Wagner Law Group, widely recognized as the country’s top ERISA and employee benefits law firm, announced the expansion of the firm’s St. Louis office with the addition of ERISA attorney Dannae L. Delano as partner, labor and employment attorney Ivan L. Schraeder as “of counsel”, and Margaret A. Fuhr as paralegal.
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As 2018 dawns, when will PHH be decided?
Posted Date: Wednesday, December 27, 2017
It has been 223 days since the en banc panel at the D.C. Circuit Court of Appeals heard the PHH Corp. v. CFPB case.
In that time, the court has issued more than 250 opinions and judgments – including a ruling in the Lucia v. SEC case which the en banc panel heard on the same May 24 hearing that that the PHH case had.
Since the hearing, the Consumer Financial Protection Bureau has found itself back in D.C. court, but a different court, and for different reasons. But what is the future of the PHH ruling?
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Small change leads to big conversation
Posted Date: Wednesday, December 27, 2017
A small change to the tagline used in press releases issued by the Consumer Financial Protection Bureau (CFPB) caused quite a stir from observers.
The change came as the CFPB issued statements Dec. 21 about activity regarding upcoming rulemaking covering the prepaid card industry and the Home Mortgage Disclosure Act.
Read on for more about what caught the attention of industry observers.
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New complaint met with same opposition
Posted Date: Wednesday, December 27, 2017
After having one of her two RESPA counts denied without prejudice, a Florida borrower filed a second amended complaint against her loan servicer, seeking to restore a statutory damages claim.
The servicer responded, including many of the arguments which the court rejected in denying four counts of a motion to dismiss.
Read on to see what the Florida district court had to say to the loan servicer about its opposition.
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Does state foreclosure ruling bar RESPA complaint?
Posted Date: Wednesday, December 27, 2017
After losing a foreclosure action in state court, is a borrower barred by the Rooker-Feldman doctrine from alleging a RESPA violation against their servicer?
The question arose in a New Jersey court case where the borrower alleged the servicer made contradictory statements regarding the denial of her loan modification.
Read on to find out how the district court examined the complaint under Rooker-Feldman, res judicata, collateral estoppel and Rule 12(b)(6).
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Senate approves HUD nominees, but not FHA commissioner
Posted Date: Wednesday, December 27, 2017
Before adjourning for the Christmas break, the Senate approved three presidential nominees to the Department of Housing and Urban Development (HUD) by voice vote.
One of the nominees which did not get sent along, however, was President Donald Trump’s choice to be commissioner of the Federal Housing Authority.
Mortgage Bankers Association Associate Vice President of Legislative Affairs Len Wolfson was one of the nominees approved. Read on for information about the others – and the notable omission.
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OCC finds continued strength in mortgage performance
Posted Date: Wednesday, December 27, 2017
Nearly 95 percent of the 18.4 million mortgages reviewed by the Office of the Comptroller of the Currency (OCC) were current and performing at the end of the third quarter of 2017.
The quarterly review, captured in the OCC Mortgage Metrics Report, showed that performance was unchanged from the previous quarter.
Read on for more insights from the regulator’s report.
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Tweet enters CFPB hearing dispute
Posted Date: Wednesday, December 27, 2017
For nearly two hours Nov. 22, attorneys for Leandra English and the federal government pled their case in front of D.C. District Court Judge Timothy J. Kelly in the next step in the dispute over leadership of the Consumer Financial Protection Bureau.
For the first time, according to reports from observers on site, the president himself became a focus of the arguments.
Read on for initial reports from the courtroom on English’s request for a temporary restraining order against Mulvaney’s appointment.
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Quiet release for CFPB rulemaking agenda
Posted Date: Wednesday, December 27, 2017
Quietly, the Consumer Financial Protection Bureau’s Fall 2017 rulemaking agenda was released, as President Donald Trump made a public announcement about the overall deregulation work his administration has done throughout the year.
With the bureau in the middle of a 30-day freeze initiated by acting director Mick Mulvaney, few changes have been made to the agenda from the Spring 2017 announcement.
However, for the first time since the bureau released its initial agenda in 2013, the release of the Fall 2017 unified agenda was not accompanied by a blog post written by Assistant Director of Regulations Kelly Cochran.
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Report says new faces join CFPB
Posted Date: Wednesday, December 27, 2017
Although the Consumer Financial Protection Bureau (CFPB) has been under a hiring freeze since acting director Mick Mulvaney came aboard, a recent published report says Mulvaney told CFPB staff he was adding six new faces to the bureau.
The Intercept reported that Mulvaney sent a memo to staff Dec. 21 which included the six names, three of whom are staffers from the Office of Management and Budget (OMB), who will reportedly split time between the CFPB and OMB, as Mulvaney does.
Read on to learn about the new additions, including one who already has publicly acknowledged the new role.
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Mulvaney freeze period expires
Posted Date: Wednesday, December 27, 2017
When Mick Mulvaney started his first day as acting director at the Consumer Financial Protection Bureau (CFPB), he instituted a 30-day freeze on hiring; on new rules, regulation and guidance; and on any payments from the Civil Penalties Fund.
That 30-day period ended Wednesday, so what’s next? The CFPB jumped the gun on the freeze regarding regulations, and a published report said it announced plans on the hiring freeze as well.
Read on to see where the acting director is taking the bureau as 2017 comes to a close.
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Borrower sues after sending 20 QWRs
Posted Date: Wednesday, December 27, 2017
A borrower who claimed he wrote more than 20 qualified written requests (QWRs) over a three-year period sued his servicer for failing to compliantly respond to them.
The Eastern District of California District Court looked into the statute of limitations on the requests made, as well as whether the QWRs were directed toward servicing information or loan modification information.
Read on to see whether the court ruled that the borrower met the standard of a QWR, and whether he adequately pled actual damages.
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CFPB changes course on HMDA
Posted Date: Thursday, December 21, 2017
Eleven days before lenders are required to start collecting new data under the Home Mortgage Disclosure Act (HMDA), the Consumer Financial Protection Bureau came out with a public statement saying, in essence, the industry will have a one-year trial period under the new rule. And that it will engage in new rulemaking that will specifically target discretionary data points, among other areas in the HMDA rule.
The move comes the same week in which the CFPB dropped a request for collecting information related to debt collection rulemaking, as acting director Mick Mulvaney begins to leave his mark on the bureau’s work.
In a public statement released Thursday afternoon the bureau said it would not penalize the industry for HMDA data collection errors in 2018.
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CFPB leadership dispute back in court Friday
Posted Date: Thursday, December 21, 2017
The stage is set for the next battle for control of the Consumer Financial Protection Bureau (CFPB), as lawyers for President Donald Trump and acting director Mick Mulvaney meet lawyers for Deputy Director Leandra English in Judge Timothy Kelly’s court at 10 a.m. Friday.
The hearing will discuss English’s filing for a preliminary injunction against the president’s appointment of Mulvaney, who has expanded his visibility in the role beyond the CFPB’s doors.
That is one of the new areas of dispute which English’s attorneys have brought up since the government won Kelly’s ruling on a temporary restraining order. Read on to get yourself ready for the hearing.
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D.C. appeals court opens live streaming
Posted Date: Thursday, December 21, 2017
Industry members who are interested in following appellate cases involving federal regulators, but can’t attend a hearing in Washington D.C., will have a new option available.
The D.C. Circuit Court of Appeals announced that it would make live audio streaming of oral arguments available upon request.
Read on for details about the move, including how to access live streaming audio of arguments.
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Fannie, Freddie strike deal to build capital
Posted Date: Thursday, December 21, 2017
With a deadline looming that would drop the capital buffer to zero for Fannie Mae and Freddie Mac, federal regulators announced they reached agreement on a plan that would allow the government-sponsored enterprises to retain capital.
“Treasury’s first duty is to ensure that taxpayers are being protected,” Treasury Secretary Steven T. Mnuchin said in a press release.
What does the plan mean for Fannie and Freddie, and what could happen which would cancel it? Read on for the details.
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Loan officers aren’t as old as they appear, report finds
Posted Date: Thursday, December 21, 2017
The latest Stratmor Insights Report looked into results of Stratmor Group’s surveys over the past four years to determine whether loan officers are too old to meet the needs of younger borrowers, as some anecdotally believe.
What the company found is that loan officers overall aren’t as old as many believe.
The average and median age of loan officers was between 46 and 47 years old, the report stated. How does that compare to the rest of the industry? And does a loan officer’s age matter to borrowers? Read on for more.
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McDonald Hopkins welcomes attorney Julie Micalizzi
Posted Date: Wednesday, November 22, 2017
Attorney Julie A. Micalizzi has joined the Cleveland office of McDonald Hopkins LLC, a business advisory and advocacy law firm, as an associate in the Intellectual Property Department.
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Waller Lansden Dortch & Davis ranked in 2018 “Best Law Firms”
Posted Date: Wednesday, November 8, 2017
For the ninth consecutive year, Waller was nationally recognized in the “Best Law Firms” rankings published by U.S. News & World Report and Best Lawyers. With more than 230 attorneys in Austin, Birmingham, Memphis and Nashville, Waller earned rankings in 72 of the 74 curated practice areas covered by the 2018 Edition of "Best Law Firms," with every office receiving top tier recognition.
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