A&B Abstract This blog post is part five of a five-part series examining the Consumer Financial Protection Bureau’s (the “CFPB” or “Bureau”) proposed rule amending Regulation F (the “Proposed Rule”), which implements the Fair Debt Collection Practices Act (“FDCPA”) to prescribe rules governing the activities of debt collectors. The idiom “the devil is in the […]
About Nanci Weissgold
Maryland Clarifies New Net Worth Requirements for Mortgage Servicers
A&B Abstract: Effective October 1, 2019, the Maryland Commissioner of Financial Regulation will impose new net worth requirements on licensees. Importantly, Maryland servicing licensees without GSE approvals may not use a line of credit to satisfy the net worth requirements. However, mortgage servicers may include mortgage servicing rights in the calculation of tangible net worth. […]
Appraisal Reform Act of 2019 Would Impact TRID
A&B Abstract: If enacted, the recently introduced Appraisal Reform Act of 2019 would amend RESPA to require the disclosure of the appraisal management fee separate from the appraisal fee on the loan estimate (LE) and closing disclosure (CD). This could impose an additional burden on lenders and appraisal management companies (AMCs). Background The LE provides […]
Connecticut Officially Becomes an Attorney Closing State
A&B Abstract: Effective October 1, 2019 only Connecticut licensed attorneys can conduct real estate closings in the state for certain mortgage loan transactions. Real Estate Closings The process of closing a loan generally involves four core functions: transferring title to the buyer; transmitting payment to the seller (usually through an escrow agent); discharging any outstanding […]
Will the CFPB find its Voice on “Abusiveness”?
On June 25, the Consumer Financial Protection Bureau (“CFPB” or the “Bureau”) kicked off its symposia series with a panel discussion of whether the Bureau should use its rulemaking authority to further define “abusive acts or practices.” The Dodd-Frank Act added a prohibition on abusive acts and practices to the established prohibition on unfair acts and […]