A&B ABstract: The CFPB’s inconsistent statements about the need for flexibility to address the pandemic suggest a deeper game afoot. CFPB warns that continued COVID flexibility for financial institutions is not prudent… On March 31, 2021, the CFPB announced it would be rescinding seven policy statements issued last year that provided financial institutions with flexibilities […]
COVID-19
CFPB Issues Warning to Mortgage Servicing Industry
A&B ABstract: On April 1, 2021, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) issued a Compliance Bulletin and Policy Guidance (the “Bulletin”) on the Bureau’s supervision and enforcement priorities with regard to housing insecurity in light of heightened risks to consumers needing loss mitigation assistance once COVID-19 foreclosure moratoriums and forbearances end. The Bulletin […]
Consolidated Appropriations Act Includes Temporary Provisions That May Affect Servicers
Among the myriad provisions of H.R. 133, the Consolidated Appropriations Act, 2021, is Division FF, Title X, Section 1001, of which mortgage holders and servicers should take note because it may affect activities with respect to borrowers in bankruptcy. These temporary provisions expire December 27, 2021. First, Section 1001 provides that a debtor under a […]
Alston & Bird Analyzes New Guidance on Remote Work in Client Alert
As the COVID-19 pandemic continues to persist across the nation, some state regulators have begun to consider, or have adopted, measures to allow employees of licensed entities to work from home, both during the pandemic and permanently thereafter. Alston & Bird has issued a client alert unpacking a pair of state rules that extend or […]
Update: The Federal Moratorium On Residential Evictions Faces A New Class Action
A&B ABstract: The National Apartment Association, along with several landlords, has challenged the order of the Centers for Disease Control and Prevention (“CDC”) that imposed a nationwide moratorium on certain residential evictions. This lawsuit follows one we previously covered, and could have a major impact on the scope of federal power during the pandemic. Refresher […]