By Faye Ricci on Posted in Basel III,Mortgage Servicing,Regulation AB,Regulatory DevelopmentsBasel III As we start of the New Year, I think it is a good idea to assess Basel III’s impact on banks. We have just finished year one of the five year phase in of Basel III. As many of you are well aware, when the Federal Reserve Board approved the Basel III Regulatory Capital and… Continue Reading
By Faye Ricci on Posted in CFPB,Regulatory DevelopmentsIn a previous blog post, we noted that the Department of Defense (DOD) has proposed expanding the scope of Military Lending Act (MLA) protections to service members and their dependents on all payday loans, vehicle title loans, refund anticipation loans, deposit advance loans, installment loans, unsecured open-ended lines of credit, and credit cards. In 2007,… Continue Reading
By Faye Ricci on Posted in CFPB,Mortgage Servicing,Regulatory DevelopmentsOn November 20, 2014, the CFPB proposed several amendments to the mortgage servicing rules under Regulation X and Regulation Z, after previously implementing amendments to these regulations in January, 2014. As previously described in this blog, the prior amendments addressed 9 key areas and included rules governing the transfer of servicing between servicers. The new… Continue Reading
By Faye Ricci on Posted in Regulatory DevelopmentsOn September 9, 2014, Governor Jerry Brown of California signed Bill No. 2365 which prohibits a contract or proposed contract for the sale or lease of consumer goods or services from including “non-disparagement clauses” in the contract. “Non-disparagement clauses” are clauses that waives a person’s right to review: the seller, lessor or its employees or agents;… Continue Reading
By Faye Ricci on Posted in CFPB,Mortgage Servicing,Regulatory Developments,UDAAPOn September 29, 2014, the CFPB took action against Flagstar Bank for violating the CFPB’s new mortgage servicing rules by “illegally blocking borrowers’ attempts to save their homes.” The CFPB focused on the Flagstar’s actions from 2011 to present and found that Flagstar failed to devote sufficient resources to administering loss mitigation programs for distressed… Continue Reading
By Faye Ricci on Posted in CFPB,Mortgage Servicing,Regulatory Developments,TILA/RESPAOn October 22, 2014, the CFPB finalized amendments granting nonprofit small servicers an exemption from new mortgage servicing rules. These mortgage servicing rules are part of several rules regulating mortgages, including the Ability-to-Repay rules, that went into effect on January 10, 2014. The servicing related changes impacts nine key areas: Periodic billing statements Interest rate… Continue Reading
By Faye Ricci on Posted in CFPB,Regulatory DevelopmentsOn September 29, 2014, the Department of Defense (DOD) published a proposed rule amending the Military Lending Act, which expands the scope of the Military Lending Act Protections. The CFPB appeared to be taking a strong role in developing the DOD’s proposal by issuing a press release of its own supporting the DOD’s actions. The proposal would… Continue Reading
By Faye Ricci on Posted in Regulation AB,Regulatory DevelopmentsOn August 27, 2014, the SEC unanimously adopted the final rules under Regulation AB that substantially revises the offering process, disclosure and reporting requirements for registered offerings of asset-backed securities. While the rules implement many key reforms, the SEC deferred taking action on several aspects of its original rule proposals. For a copy of the… Continue Reading
