A&B Abstract: Effective October 1, 2019, the Maryland Commissioner of Financial Regulation will impose new net worth requirements on licensees. Importantly, Maryland servicing licensees without GSE approvals may not use a line of credit to satisfy the net worth requirements. However, mortgage servicers may include mortgage servicing rights in the calculation of tangible net worth. […]
State Law
New York DFS Launches Research and Innovation Division
A&B Abstract: In an effort to position itself as the “Regulator of the Future,” the New York State Department of Financial Services (“NYDFS”) recently launched the Research and Innovation Division, which will be responsible for ensuring that the NYDFS keeps pace with the rapid changes in all sectors of the financial services industry. Earlier this […]
Will Maine begin to regulate passive, secondary market investors in student loan debt?
A&B Abstract: Maine’s New Student Loan Bill of Rights requires the licensing of any person acting as “directly or indirectly” as a student loan servicer. What might that mean for passive, secondary market investors in student loan debt? Background On June 20, 2019, Maine Governor Janet Mills signed into law LD 995, Maine’s “Student Loan […]
Potential Changes to the CCPA; California Senate Considers Amendments
On April 30, we detailed several proposed amendments to the California Consumer Privacy Act (the “CCPA”) that were advancing in the State Assembly (see our previous blog post here). Since then, a number of the proposed amendments passed the Assembly and moved to the California Senate, where they remain under consideration. This past week the Judiciary […]
Connecticut Officially Becomes an Attorney Closing State
A&B Abstract: Effective October 1, 2019 only Connecticut licensed attorneys can conduct real estate closings in the state for certain mortgage loan transactions. Real Estate Closings The process of closing a loan generally involves four core functions: transferring title to the buyer; transmitting payment to the seller (usually through an escrow agent); discharging any outstanding […]