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Stephen Ornstein

About Stephen Ornstein

Stephen Ornstein, co-leader of the firm’s Consumer Financial Services Team, concentrates on federal and state mortgage banking, consumer credit and ancillary services regulatory issues.

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Second Juneteenth Holiday Raises Tricky Compliance Issues

June 10, 2022 By Stephen Ornstein

A&B Abstract The second observance of the Juneteenth National Independence Day (Juneteenth) holiday is Monday, June 20, 2022.  President Biden signed legislation making Juneteenth National Independence Day a federal national holiday last year. Because the fixed date holiday falls on a Sunday, the second observance of Juneteenth raises tricky compliance issues for the timing of […]

Filed Under: Consumer Financial Protection Bureau (CFPB), TRID Tagged With: #CFPB, #Juneteenth, TRID

Utah to regulate smaller commercial non-real estate secured financings

April 18, 2022 By Stephen Ornstein

A&B Abstract: We wanted to apprise you of a significant development impacting the commercial non-real estate secured lending arena which until recently has been lightly regulated by the states.  On March 24, 2022, Utah Governor Spence Cox signed into law S.B. 183, the “Commercial Financing Registration and Disclosure Act” (the “Act”) which, commencing on January […]

Filed Under: State Law Tagged With: #commercialfinancing, #Utah

California, New York Create Disclosure Requirements for Commercial Financing Transactions

November 3, 2021 By Stephen Ornstein

A&B ABstract: As a general matter, state regulation of commercial lending is relatively light, and few states impose licensing requirement on commercial loan origination.  In two noteworthy state developments, however, California and New York will require loan “providers” to furnish certain consumer-like disclosures to prior to the consummation of commercial financing transactions. The California requirements […]

Filed Under: California, State Law Tagged With: #commercial, #mezzanine

Juneteenth Holiday Raises Tricky TRID Disclosure Issues

June 18, 2021 By Stephen Ornstein

On June 17, 2021, President Biden signed legislation making Juneteenth National Independence Day a federal national holiday. The first observance of the holiday is Friday, June 18, 2021. While the enactment of this new federal holiday is a notable and welcome national event, its first observance has immediate consequences for the timing of certain disclosures […]

Filed Under: Mortgage Loans, TRID Tagged With: #Juneteenth

The QM Patch Is Down for the Count

June 9, 2021 By Stephen Ornstein

Whether they realize it or not, absent a last-minute intervention from the Federal Housing Finance Agency (FHFA), effective July 1, 2021, creditors will no longer be able to originate qualified mortgage loans using the “QM Patch.” The reason for this dramatic event is that on April 8, 2021, Fannie Mae and Freddie Mac announced in separate […]

Filed Under: Ability to Repay/Qualified Mortgage, Consumer Financial Protection Bureau (CFPB), Federal Housing Finance Agency (FHFA) Tagged With: #QMPatch, QM

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