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Britney Crawford is an associate in the firm’s Banking and Financial Services Practice Group. Her practice is focused on regulatory and compliance matters related to financial and mortgage institutions and lenders. Britney also has experience assisting clients in responding to and resolving government investigations by federal regulators.

In October 2023, the CFPB issued an advisory opinion titled, “Consumer Information Requests to Large Banks and Credit Unions.” The upshot of the advisory opinion is that covered financial institutions responding to consumer information requests under Section 1034(c) of the Consumer Financial Protection Act (CFPA) face significant limitations on the fees they can charge to

Consistent with its mission to safeguard against fraud, waste, and abuse, the Office of Inspector General (OIG) of the U.S. Department of Housing and Urban Development (HUD) recently announced concerns regarding Ginnie Mae’s management of its Home Equity Conversion Mortgage-Backed Securities (HMBS) Program.

On November 15, 2023, the HUD OIG issued the Top Management Challenges

On November 16, 2023, in response to comments received on a prior draft Mortgagee Letter (ML) related to a Proposed Payment Supplement Partial Claim, the Federal Housing Administration (FHA) published another draft ML titled “Payment Supplement.” The prior draft ML proposed a payment supplement partial claim that would cure mortgage arrearages and

On September 19, the Consumer Financial Protection Bureau (CFPB) issued Circular 2023-03, which provides guidance as to how lenders must explain denials of applications of credit when the underwriting is based on artificial intelligence (AI) or complex credit models. The upshot of the guidance is that a lender that denies an application for credit

On May 31, 2023, the Federal Housing Administration (FHA) published a draft Mortgagee Letter (ML) titled “Proposed Payment Supplement Partial Claim.” The draft ML proposes use of available partial claims funds to create a new loss mitigation option to assist struggling borrowers.

Generally, a partial claim is an interest-free subordinate loan issued by

Consistent with concerns surrounding bias in property valuations, on June 8, 2023, the Consumer Financial Protection Bureau (CFPB), the Federal Deposit Insurance Corporation (FDIC), the Board of Governors of the Federal Reserve System (the “board”), the National Credit Union Administration (NCUA), and the Office of the Comptroller of the Currency (OCC) issued proposed guidance on

In a continuation of enforcement activity related to redlining under October 2021’s Combatting Redlining Initiative, the U.S. Department of Justice (DOJ) announced on May 31, 2023, that ESSA Bank & Trust has agreed to pay $3 million to settle allegations that it engaged in redlining, a discriminatory practice in which lenders fail to provide

Affirming its commitment to the senior citizen population, on May 17, 2023, the Federal Housing Administration (FHA) issued Mortgagee Letter 2023-10, implementing amendments to the Home Equity Conversion Mortgage (HECM) assignment claim submission criteria.

As a bit of background, a HECM is a reverse mortgage insured by the FHA. HECMs, as any reverse mortgage

In light of growing concerns, the Federal Financial Institutions Examination Council (FFIEC) Appraisal Subcommittee (ASC) held its first hearing on appraisal bias on January 24, 2023, at the Consumer Financial Protection Bureau (CFPB) headquarters. The FFIEC, a federal interagency body comprised of the Board of Governs of the Federal Reserve System (FRB), Federal Deposit Insurance

On December 15, 2022, the Federal Housing Administration (FHA) issued Mortgagee Letter 2022-23, establishing the COVID-19 Home Equity Conversion Mortgage (HECM) Property Charge Repayment Plan.

The COVID-19 HECM Property Charge Repayment Plan would aid HECM borrowers in covering costs associated with standard property charges. As a condition of their loan, HECM borrowers are required