Bank Notes

  • May 6, 2016
    On Wednesday, May 4, 2016, the Federal Housing Finance Agency (FHFA) announced it has increased the 2016 multifamily lending caps for Fannie Mae and Freddie Mac from $31 billion to $35 billion, effective immediately. The adjustment is consistent with FHFA's 2016 Scorecard for the Enterprises in which FHFA committed to review the estimates for the size of the multifamily finance market each...
  • May 6, 2016
    On Friday, April 29, 2016, the Federal Financial Institutions Examination Council (FFIEC) issued a request for comment on a proposal to revise the Uniform Interagency Consumer Compliance Rating System, more commonly known as the " CC Rating System ," to reflect the regulatory, examination (supervisory), technological, and market changes that have occurred in the years since the current rating...
  • May 6, 2016
    Last week, the CFPB released its fourth Fair Lending Report outlinging the agency’s fair lending activity in 2015. A few notable items include: Regarding indirect auto, CFPB Director Director Cordray “urge[d] indirect auto lenders to carefully consider the terms of these orders as they evaluate compliance in their own lending programs.” Last year, the Office of Fair Lending and Equal Opportunity...
  • May 6, 2016
    On April 28, 2016, Rep. Blaine Luetkemeyer (R-MO) introduced H.R. 5112 , the Unfair or Deceptive Acts or Practices (UDAP) Uniformity Act. The bill would eliminate the vaguely defined “abusive” standard created by Section 1031 of the Dodd-Frank Act. Since the passage of the Dodd-Frank Act, the CFPB has not issued any guidance to define abusive practices, thereby making compliance with the standard...
  • April 28, 2016
    On Thursday, April 28, 2016, CBA sent a letter to Congressmen Blaine Luetkemeyer (R-MO) and Randy Neugebauer (R-TX) thanking them for their continued oversight of the CFPB and its implementation of the TRID rules. In its letter, CBA explained the continued complications banks encounter in establishing operational systems to merge TILA and RESPA, which has led to longer closings for consumers as...
  • April 28, 2016
    On Thursday, April 28, 2016, the CFPB released its student loan Payback Playbook , a set of prototype disclosures designed to outline a path to affordable payments for borrowers trying to avoid student debt distress. The Payback Playbook provides borrowers with personalized information about their repayment options from loan servicers so they can secure a monthly payment they can afford. The...
  • April 26, 2016
    On Tuesday, April 26, 2016, the Bureau released the Monthly Complaint Report which focused on mortgage complaints and complaints received from California. According to the report, as of April 1, 2016, the CFPB has handled approximately 859,900 total complaints, including 26,500 complaints in March 2016, and 223,100 mortgage complaints, and 118,900 from California. Other notably takeaways include...
  • April 26, 2016
    On Tuesday, April 26, 2016, the CFPB released the results of a report conducted by Fors Marsh Group, titled: “Testing of Bankruptcy Periodic Statement Forms for Mortgage Servicing.” The Bureau commissioned the survey to test sample bankruptcy-specific periodic statement forms. The forms were developed using suggestions collected during the comment period for the proposed amendments to Regulation...
  • April 25, 2016
    On Monday, April 25, 2016, the CFPB entered into a consent order with a debt collection law firm Pressler & Pressler LLP and debt buying firm New Century Financial Services, Inc. The Bureau alleges the firm engaged in violations of the Fair Debt Collection Practices Act and the ban on unfair, deceptive or abusive acts and practices when it “filed hundreds of thousands of lawsuits against...

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