Bank Law Monitor

Bank Law Monitor

A Legal Blog for the Financial Services Industry

Tag Archives: Loans

FinCEN Reverses Course on Beneficial Ownership Requirements in Connection with Loan Renewals and Modifications

Posted in Banking, Regulatory Developments
It can be hard for regulatory agencies to admit when they’ve made a mistake. But that’s exactly what FinCEN did last week when it announced that certain loan renewals and modifications[1] would not trigger its beneficial ownership due diligence rule (the “Rule”), reversing its earlier guidance on the subject. FinCEN’s change of heart is welcome… Continue Reading

The Shifting Sands of Washington’s Consumer Loan Act

Posted in Banking, CFPB, Mortgage Servicing
Since the Great Recession, the regulation of residential mortgages and those who service them have been in sharp focus. Legislators and regulators continue to demonstrate an abiding mistrust in the servicing industry a full decade after the financial collapse—imposing and then tinkering with a regulatory scheme that is challenging for most people (and most lawyers,… Continue Reading