Feel like you’re in a shaken snow globe? So do we! February brought the worst “vacation” we’ve seen when the industry-favorable PHH decision was vacated. We’ll have to await the en banc review for a ruling on the CFPB’s constitutionality…
Blog Archives
Fall 2016 From The Trenches
In its Fall Supervisory Highlights, the CFPB addressed its latest supervisory observations relative to mortgage origination and mortgage servicing. These are issues the CFPB has encountered during examinations, and are therefore areas to which mortgage lenders and servicers may wish…
Posted in Hot Topics, Newsletters
Big Win for PHH in Case Against CFPB
The U.S. Court of Appeals for the DC Circuit has released its opinion in PHH’s case against the CFPB, and it’s a resounding win for PHH and the industry. In its 110-page opinion, the Court vacated the CFPB’s order against…
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CFPB Issued Proposed Revisions to TRID Rules
The CFPB issued a proposed rule which amends and clarifies various provisions of TRID. Comments on the proposal are due by October 18, 2016. The proposal addresses several concerns regarding TRID which have been ongoing since the rule’s implementation. The…
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Labor Department Issues Final OT Expansion Rule
On May 18, 2016, the Department of Labor (“Department”) announced it will publish a Final Rule updating regulations related to overtime compensation and exemption provisions for executive, administrative and professional employees, as well as for Highly Compensated Employees under the…
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Careful what you wish for … CFPB Guidance on MSAs
After weeks of hinting, today the CFPB issued Compliance Bulletin 2015-05 trumpeting louder than ever its concern over marketing services agreements (MSAs). While MSAs are not per se illegal, it is clear that the CFPB is suspicious about the legitimacy…
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CFPB Responds to Wells Fargo Decision to End MSAs
Last week, Wells Fargo and Prospect Mortgage announced their intentions to end marketing service agreements with builders and brokers. In response to Wells Fargo’s announcement, the CFPB issued the following statement: “Wells Fargo’s decision to exit all marketing services agreements…
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Summer 2015 Hot Topics
CFPB Finalizes Extension of TRID Effective Date to October 3rd The Consumer Financial Protection Bureau issued a Final Rule delaying the effective date of the TILA-RESPA Integrated Disclosures Rule until October 3rd, 2015. The Final Rule also makes two technical…
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Supreme Court Holds That Fair Housing Act Authorizes Disparate-Impact Claims
U.S. Supreme Court Holds That Fair Housing Act Authorizes Disparate-Impact Claims The Supreme Court held today, in Texas Dept. of Housing and Community Affairs v. Inclusive Communities Project, that the Fair Housing Act authorizes claims based on a theory of…
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CFPB PLANS TO DELAY TRID EFFECTIVE DATE
The CFPB just announced its plans to issue a proposed amendment to delay the effective date of the Integrated Disclosure rule until October 1, 2015. Specifically, the statement provides: “The CFPB will be issuing a proposed amendment to delay the…
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