A&B ABstract: In a reversal of its previous position on the issue, the CFPB publicly asserted last month in two separate venues that the for-cause removal provision of the Consumer Financial Protection Act is unconstitutional. On September 17, … [Continue reading] about CFPB Changes Tack on For-Cause Removal Provision
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 … [Continue reading] about Agencies Raise Appraisal Threshold Exemption
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. … [Continue reading] about CSBS’s State Examination System Coming Soon
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 … [Continue reading] about New York Proposes Student Loan Servicing Rules
A&B Abstract: What happens when a proposed qualified mortgage is later discovered to have points and fees in excess of the statutory threshold? The answer lies in a cure provision scheduled to sunset on January 21, 2021. CFPB Rules Permit … [Continue reading] about CFPB Rules Permit Qualified Mortgage “Cures”