The New York Department of Financial Services (“NYDFS”) has issued final mortgage servicer business conduct rules found in Part 419 of the Superintendent’s Regulations. As we reported in June, these represent the first major changes to Part 419 since its adoption nearly 10 years ago. Our full analysis of the changes – which impact a […]
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CFPB Issues New Edition of Supervisory Highlights
A&B ABstract: The Fall 2019 edition of the CFPB’s Supervisory Highlights focuses on credit reporting issues of interest. Discussion The Fall 2019 edition of Supervisory Highlights represents the second time the Consumer Financial Protection Bureau (“CFPB”) has focused entirely on credit reporting. With respect to furnishers, the Supervisory Highlights includes five categories of supervisory observations […]
CFPB Issues Final HMDA Rule Incorporating Reporting Exemptions
A&B ABstract: In a final rule issued on October 10, 2019, the CFPB amended Regulation C under the Home Mortgage Disclosure Act to incorporate exemptions created by the Economic Growth, Regulatory Relief, and Consumer Protection Act, among other changes. Discussion: Effective January 1, 2020, the Consumer Financial Protection Bureau issued a final rule under the […]
Agencies Raise Appraisal Threshold Exemption
A&B ABstract: A new rule from the federal banking regulators reduces the number of residential mortgage transactions for which an appraisal is required. The rule also incorporates changes to federal appraisal requirements made by the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018. On September 27, 2019, the Federal Deposit Insurance Corporation, the […]
CFPB Issues New Edition of Supervisory Highlights
A&B Abstract: The Summer 2019 edition of the CFPB’s Supervisory Highlights indicates recent examination focuses for several categories of consumer credit products. CFPB Issues New Edition of Supervisory Highlights On September 19, the Consumer Financial Protection Bureau (“CFPB”) issued the Summer 2019 edition of Supervisory Highlights, detailing examination findings relating to automobile loan origination, […]