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 […]
Mortgage Loans
South Carolina Revisiting Borrower Preference Requirements
A&B ABstract: The South Carolina Department of Consumer Affairs (“Department”) announced that it is soliciting comments on proposed Regulation 28-75, which would provide mortgage lenders with additional guidance on the state’s attorney and insurance agent borrower preference requirements. Determination of Borrower Preferences Section 37-10-102 of the South Carolina Consumer Protection Code requires a creditor […]
Massachusetts Settlement Agreements Highlight AG’s Compliance Expectations
A&B Abstract: In a series of 2019 settlement agreements, the Massachusetts Attorney General has publicly provided insights into her compliance expectations for residential mortgage servicers. The settlements demonstrate a focus on compliance with the Commonwealth’s Act to Prevent Unlawful and Unnecessary Foreclosures, codified in part as M.G.L. Chapter 244, Section 35B (“Section 35B”) and its […]
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 […]
CSBS’s State Examination System Coming Soon
A&B ABstract The Conference of State Bank Supervisors (CSBS) revolutionized state licensing with the National Mortgage Licensing System (NMLS) by providing a more uniform approach to state licensing of non-bank financial services companies. CSBS will bring a similar transformation to supervising such companies. The New State Examination System CSBS designed the State Examination System (SES) […]