A&B Abstract: On April 23, 2020, the attorneys general of 33 states, the District of Columbia and Puerto Rico (the “Attorneys General”) sent two letters, one to the Federal Housing Finance Agency (“FHFA”) and the other to the U.S. Department of Housing and Urban Development (“HUD” and collectively with FHFA, the “Agencies”), respectively, noting that […]
Servicing
Regulatory Agencies Issue Mortgage Servicing Guidance and FAQs for the CARES Act
Our Financial Services & Products Group answers some questions mortgage servicers might have about how federal and state agencies will be flexible with enforcement under the CARES Act. What is the “covered period” for purposes of Section 4022? Can a servicer require a borrower to provide a written attestation? Should servicers report the status of […]
Key Provisions of the CARES Act Affecting Mortgage Servicers
A&B ABstract: In response to COVID-19, on Friday March 28, 2020, President Trump signed into law the “Coronavirus Aid, Relief, and Economic Security Act” (the “CARES Act”). This is a monumental $2 trillion stimulus package intended to provide financial relief to businesses, individuals and public institutions affected by the coronavirus. The CARES Act addresses sweeping […]
Federal and State Guidance Regarding the COVID-19 Pandemic
A&B Abstract: The Alston & Bird Consumer Finance team recognizes that this is a period of great uncertainty both for the nation and our clients. We have received numerous questions and concerns regarding what federal and state regulators are doing in light of the COVID-19 pandemic and how their response may affect day-to-day business. We […]
NYDFS Extends Transition Period for Part 419 Compliance by Additional 90 Days
On March 13, 2020, the New York Department of Financial Services (“NYDFS”) adopted, on an emergency basis, amendments (the “Emergency Adoption”) to the final mortgage servicer business conduct rules found in Part 419 of the Superintendent’s Regulations (the “Final Rules”), to extend the transition period for compliance with the Final Rules by an additional 90 […]