A&B Abstract: Purchasers of residential mortgage loans who are conducting audits of residential mortgages that they buy in the secondary market are struggling to determine what documentation satisfies the “consider” requirement of the revised … [Continue reading] about Complying with the “Consider” Requirement Under the Revised Qualified Mortgage Rules
CFPB’s Message to Mortgage Servicers: Make Sure You Comply with RESPA’s Force-Placed Insurance Requirements
A&B Abstract: In Case You Missed It: At the recent Federal Housing Finance Agency’s Symposium on Property Insurance, CFPB Director Rohit Chopra spoke about force-placed insurance and conveyed the following message: “The CFPB will be carefully … [Continue reading] about CFPB’s Message to Mortgage Servicers: Make Sure You Comply with RESPA’s Force-Placed Insurance Requirements
Correspondent Lending on the Rise: Increasing Gains Point to Increasing Risk
A&B Abstract: According to a recent edition of Inside Mortgage Finance, correspondent lending is the only lending channel that posted gains in Q3 2023. While it is always nice to see gains, it should also serve as a reminder to take a fresh … [Continue reading] about Correspondent Lending on the Rise: Increasing Gains Point to Increasing Risk
FSOC Approves Analytic Framework for Financial Stability Risks and Guidance on Nonbank Financial Company Designations
A&B Abstract: On November 3, 2023 the Financial Stability Oversight Council (hereinafter “FSOC” or “Council”) unanimously approved final versions of: (1) the new Analytic Framework for Financial Stability Risk Identification, Assessment, and … [Continue reading] about FSOC Approves Analytic Framework for Financial Stability Risks and Guidance on Nonbank Financial Company Designations
NYDFS Finalizes Second Amendment to Its Cybersecurity Regulation
On November 1, 2023, the New York Department of Financial Services (NYDFS) published the finalized Second Amendment to its Cybersecurity Regulation (23 NYCRR Part 500), which includes a number of significant and, for many covered entities, onerous … [Continue reading] about NYDFS Finalizes Second Amendment to Its Cybersecurity Regulation