What Happened? On February 27, the Consumer Finance Protection Bureau (CFPB) and the Federal Trade Commission (FTC) filed an amicus brief in the 11th Circuit case Glover and Booze v. Ocwen Loan Servicing, LLC arguing that certain convenience fees … [Continue reading] about CFPB and FTC Amicus Brief Signals Stance on “Pay-to-Pay” Fees under FDCPA
Ginnie Mae Imposes Cybersecurity Incident Notification Obligation
What Happened? On March 4, 2024, Ginnie Mae issued All Participant Memorandum (APM) 24-02 to impose a new cybersecurity incident notification requirement. Ginnie Mae has also amended its Mortgage-Backed Securities Guide to reflect this new … [Continue reading] about Ginnie Mae Imposes Cybersecurity Incident Notification Obligation
Appraisal Bias Focus Continues in 2024
What Happened? Building on the 2021 announcement of the Interagency Task Force on Property Appraisal and Valuation Equity (“PAVE”) and a series of federal agency actions in the intervening months, 2024 brings new efforts at the state and federal … [Continue reading] about Appraisal Bias Focus Continues in 2024
A Friendly Reminder of the Importance of Robust Consumer Complaint Handling Processes
What Happened? On February 27, 2024, the California Department of Financial Protection and Innovation (the Department) entered into a public consent order with a company that provides consumer financial services to California residents. The … [Continue reading] about A Friendly Reminder of the Importance of Robust Consumer Complaint Handling Processes
CFPB’s Proposed Insufficient Fund Fee Rule – Narrow in Scope with Potential for Greater Impact
What Happened? On January 24, 2024, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a proposed rule that would prohibit covered financial institutions from imposing a nonsufficient funds (NSF) fee when consumers initiate … [Continue reading] about CFPB’s Proposed Insufficient Fund Fee Rule – Narrow in Scope with Potential for Greater Impact