A&B ABstract: In the wake of the recent earthquakes in Puerto Rico, the Puerto Rico Office of the Commissioner of Financial Institutions (“OCFI”) released Circular Letter No. CFI-2020-01 (the “Circular Letter”). The Circular Letter imposes weekly and monthly reporting requirements on all Puerto Rico licensed mortgage lenders, mortgage servicers, Home Equity Conversion Mortgage servicers, reverse […]
Mortgage Loans
FHFA Proposes New Minimum Financial Requirements for Fannie Mae and Freddie Mac Seller/Servicers
A&B ABstract In keeping with broader scrutiny on non-bank servicers, the Federal Housing Finance Agency (FHFA) is proposing new financial eligibility requirement for non-bank servicers doing business with Fannie Mae or Freddie Mac. The Proposal: On January 31, the FHFA proposed new financial eligibility requirements for approved nonbank Seller/Servicers doing business with Fannie Mae or […]
CFPB Director Provides Update Relating to QM Patch Expiration
A&B ABstract: A recent letter from Consumer Financial Protection Bureau (“CFPB”) Director Kathleen Kraninger provides clues about the potential future of the so-called “QM Patch.” Discussion: In a December 17, 2020 letter to Senator Mike Rounds (“Letter”), CFPB Director Kathleen Kraninger, revealed a number of interesting insights about the CFPB’s ongoing evaluation of the […]
NYDFS Issues Final Mortgage Loan Servicer Business Conduct Rules (Part 419)
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. Our January 24 client advisory provides a full analysis of the changes, which include: New provisions governing affiliated business arrangements; Expanded restrictions on servicing fees (including property valuation fees); A broader […]
FTC Announces Settlement with Mortgage Broker for Publishing Personal Information about Consumers
A&B ABstract: On January 7, 2020, the Federal Trade Commission (FTC) announced a complaint and settlement against California mortgage broker Mortgage Solutions FCS, doing business as Mount Diablo Lending, and its owner, Ramon Walker, (collectively, Mortgage Solutions). The FTC’s complaint (Complaint) alleged that in response to negative Yelp reviews posted by applicants and customers, the […]