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Illinois Proposes Rules Implementing Its Community Reinvestment Act for Banks, Mortgage Lenders, and Credit Unions

January 26, 2023 By Caroline Eisner

A&B ABstract: The Illinois Department of Financial and Professional Regulation (“IDFPR”) has issued a notice of proposed rules to implement the newly passed Illinois Community Reinvestment Act (“ILCRA”), aimed at serving the credit needs of low- and moderate-income communities and individuals.  The proposal includes a separate set of rules applicable to state-chartered banks, non-depository mortgage […]

Filed Under: Community Reinvestment Act, Mortgage Loans, State Law Tagged With: Community Reinvestment Act, CRA, Illinois, mortgage lending

CFPB Proposes Nonbank Registry to Focus on Compliance “Recidivism”

January 11, 2023 By Nanci Weissgold, Anoush Garakani and Melissa Malpass

A&B ABstract: On December 12, 2022, the Consumer Financial Protection Bureau (CFPB) announced a proposed rule to require certain non-banks to register with the agency when they become subject to a public written order or judgment imposing obligations based on violations of certain consumer protection laws. The CFPB also proposes to maintain a public online […]

Filed Under: Consumer Financial Protection Bureau (CFPB), Consumer Loan, Dodd-Frank Act, Mortgage Loans, Mortgage Servicing, Unfair, Deceptive and Abusive Acts or Practices (UDAAP) Tagged With: #CFPA, #CFPB, mortgage lending, Mortgage Servicing, Servicing

Assumptions on the Rise: Are You Ready for Mortgage Assumptions?

December 16, 2022 By Nanci Weissgold, Anoush Garakani and Melissa Malpass

A&B ABstract: Mortgage assumptions – where a buyer assumes the existing mortgage loan of a seller – have fluctuated in popularity since the 1980s. However, inflation and the high interest rate environment, coupled with an observable shift to a buyer’s market, are raising the prospect that assumable mortgages – especially those with historically low interest […]

Filed Under: Ability to Repay/Qualified Mortgage, Consumer Financial Protection Bureau (CFPB), Department of Housing and Urban Development (HUD), Licensing, Mortgage Loans, Mortgage Servicing, Real Estate Settlement Procedures Act (RESPA), TRID, Truth in Lending Act (TILA), Unfair, Deceptive and Abusive Acts or Practices (UDAAP) Tagged With: #mortgageservicing, assumablemortgage, Assumptions, HUD, mortgage lending, Mortgage Servicing, Servicing, UDAAP

HELOCs On the Rise: Is Your Servicing CMS Ready?

December 8, 2022 By Nanci Weissgold and Anoush Garakani

A&B ABstract: The Consumer Financial Protection Bureau (“CFPB” or “Bureau”) has moved to clarify its regulatory authority at a time when the economic climate is ripe for a resurgence in HELOC lending. In an amicus brief filed by the CFPB on November 30, 2022 (the “Amicus Brief”), the Bureau acknowledged that its Mortgage Servicing Rules, […]

Filed Under: Consumer Financial Protection Bureau (CFPB), Dodd-Frank Act, Fair Credit Reporting Act (FCRA), Licensing, Mortgage Loans, Mortgage Servicing, Real Estate Settlement Procedures Act (RESPA), State Law, Truth in Lending Act (TILA), Unfair, Deceptive and Abusive Acts or Practices (UDAAP) Tagged With: #CFPB, #FCRA, #mortgageservicing, #redlining, licensing, mortgage lending, Mortgage Servicing, Servicing, UDAAP

CFPB Publishes Fall 2022 Supervisory Highlights

December 1, 2022 By Anoush Garakani and Aileen Ng

A&B ABstract: On November 16, 2022, the Consumer Financial Protection Bureau (“CFPB” or “Bureau”) released its Fall 2022 Supervisory Highlights (Issue 28) (the “Supervisory Highlights”), which, among other things, announces the creation of a Repeat Offender Unit and highlights supervisory observations from examinations conducted by the Bureau in the first half of 2022.  Below we […]

Filed Under: CARES Act, Consumer Financial Protection Bureau (CFPB), COVID-19, Debt Collection, Fair Credit Reporting Act (FCRA), Fair Debt Collection Practices Act (FDCPA), Forbearance, Mortgage Loans, Mortgage Servicing, Real Estate Settlement Procedures Act (RESPA), Unfair, Deceptive and Abusive Acts or Practices (UDAAP) Tagged With: #CFPB, #debtcollection, #FCRA, #mortgageservicing, CARES Act, Covid-19, Forbearance, Mortgage Servicing, Servicing

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Recent Posts

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