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Anoush Garakani

Connecticut and Maryland Adopt Model Mortgage Servicer Prudential Standards

August 1, 2022 By Nanci Weissgold, Anoush Garakani and Josh Dhyani

A&B Abstract: On May 24, 2022, Connecticut enacted legislation that, among other things, adds financial condition and corporate governance requirements for certain licensed mortgage servicers (the “CT Standards”). In similar fashion, the Maryland Commissioner of Financial Regulation (the “Commissioner”) issued a notice of final action on March 25, 2022 adopting similar standards by regulation (the […]

Filed Under: Federal Housing Finance Agency (FHFA), Mortgage Servicing, State Law Tagged With: #GSEs, #mortgageservicing, CSBS, Mortgage Servicing, Servicing

Maryland Regulator Puts Lenders and Servicers on Notice Regarding the Assessment of So-Called “Convenience Fees”

June 8, 2022 By Anoush Garakani and Nanci Weissgold

A&B Abstract: On May 12, 2022, the Maryland Office of the Commissioner of Financial Regulation (the “OCFR”) issued an Industry Advisory (the “Advisory”) “put[ting] [the] industry on notice” of the recent decision issued by the 4th Circuit Court of Appeals in Ashly Alexander, et. al. v. Carrington Mortgage Services, LLC.  The Advisory directs lenders and […]

Filed Under: Debt Collection, Fair Debt Collection Practices Act (FDCPA), Mortgage Servicing, State Law Tagged With: #debtcollection, #FDCPA, Debt Collection, Mortgage Servicing, Regulation F, Servicing

Client Advisory: One Person’s Junk Fee Is Another’s Treasure

May 3, 2022 By Nanci Weissgold and Anoush Garakani

In a recent Financial Services & Products Advisory, Partners Nanci Weissgold and Anoush Garakani evaluate the CFPB’s recent “junk fees” initiative and its potential effect on mortgage servicing fee structures. The advisory can be accessed here.

Filed Under: Consumer Financial Protection Bureau (CFPB), Mortgage Servicing Tagged With: #CFPB, #mortgageservicing

Modern-Day Redlining Enforcement: A New Baseline

October 28, 2021 By Nanci Weissgold, Melissa Malpass and Anoush Garakani

On October 22, 2021, the U.S. Department of Justice (DOJ) announced an aggressive new initiative, in collaboration with U.S. Attorneys’ Offices throughout the country, to combat the practice of redlining. Three days prior, the Consumer Financial Protection Bureau (CFPB) was said to be hiring up to 30 new enforcement attorneys to focus on redlining and […]

Filed Under: Banking Regulatory Agencies, Consumer Financial Protection Bureau (CFPB), Equal Credit Opportunity Act (ECOA), Mortgage Loans Tagged With: #CFPB, #redlining, disparate treatment, DOJ, Fair Lending

Biden-Harris Administration Announces Extension of COVID-19 Foreclosure Moratorium

June 24, 2021 By Nanci Weissgold and Anoush Garakani

A&B Abstract: Today, the Biden Administration announced an extension of the foreclosure moratorium for federally-backed mortgage loans (the “Presidential Announcement”). To implement the Presidential Announcement, the federal agencies (i.e., HUD/FHA, USDA, and VA) and GSEs (i.e., Fannie Mae and Freddie Mac) have announced (or are anticipated to announce) extensions of the foreclosure moratorium until July […]

Filed Under: CARES Act, Consumer Loan, COVID-19, Department of Housing and Urban Development (HUD), Federal Housing Finance Agency (FHFA), Forbearance, HUD, Mortgage Loans, Mortgage Servicing Tagged With: #GSEs, Covid-19, Forbearance, Foreclosure, HUD, Mortgage Servicing, Servicing

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