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 […]
State Law
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) […]
New York Proposes Student Loan Servicing Rules
A&B ABstract Amid growing concerns over the federal government’s “hands off” approach to regulating the student loan business, New York Governor Andrew Cuomo released 3 NYCRR 409, a proposed regulation aimed at providing significant consumer protections for New York student loan borrowers, to the public for comment. The deadline for comment on the regulation is […]
California Passes Several Amendments to the California Consumer Privacy Act
The California legislature passed several amendments to the California Consumer Privacy Act of 2018 (Cal. Civ. Code §§ 1798.100 to 1798.190) (the “CCPA”) on September 13, 2019. (For additional background, see Which CCPA Amendments Made the Cut? and Potential Changes to the CCPA; California Senate Considers Amendments). These amendments will soon head to Governor Newsom’s desk for […]
A Closer Look at the CFPB’s Proposed Debt Collection Rules – Part Five: The Devil is in the Details, Purgatory is what is Left Unsaid
A&B Abstract This blog post is part five of a five-part series examining the Consumer Financial Protection Bureau’s (the “CFPB” or “Bureau”) proposed rule amending Regulation F (the “Proposed Rule”), which implements the Fair Debt Collection Practices Act (“FDCPA”) to prescribe rules governing the activities of debt collectors. The idiom “the devil is in the […]