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Jason Bushby provides regulatory compliance, examination, enforcement, and litigation assistance to a range of financial services clients across the country. He serves as counsel to the American Bankers Association and general counsel to the Alabama Consumer Finance Association. He is also a frequent speaker during webinars and trade association presentations on regulatory compliance issues.

Ginnie Mae Announces PTAP Assistance for IssuersIn an All Participants Memo dated April 10, 2020 (APM 20-03), Ginnie Mae announced that it revised and expanded its issuer assistance programs in Chapter 34 of the Mortgage Backed Securities Guide (MBS Guide) to include a Pass-Through Assistance Program (PTAP) in response to the COVID-19 national emergency declaration. The program announced in APM 20-03

Federal Financial Agencies Announce Flexibility in Enforcing Certain Mortgage Servicing Rules in Response to COVID-19On Friday, April 3, the Consumer Financial Protection Bureau (CFPB), Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), the Office of the Comptroller of the Currency (OCC) and the State Banking Regulators released a joint statement announcing increased flexibility in the agencies’ regulation

Mortgage Servicers: Keep an Eye on the CFPB’s Advice to Borrowers Impacted by COVID-19On March 31, 2020, the CFPB posted a “Guide to coronavirus mortgage relief options,” which provides instruction to mortgage loan borrowers who may be impacted by COVID-19 on when and how to go about obtaining assistance. While we have previously discussed compliance challenges that are likely to arise related to verbal loss mitigation

HUD Proposes Amendments to the Federal Manufactured Home Construction and Safety StandardsOn January 30, 2020, U.S. Department of Housing and Urban Development (HUD) Secretary Ben Carson announced the release of a proposed rule to amend the Federal Manufactured Home Construction and Safety Standards. Secretary Carson made the announcement while touring the Clayton Homes Manufacturing Plant in Russellville, Alabama. The proposed rule covers numerous changes to the

New Law Expands Protections for Manufactured Homeowners and Tenants in New YorkEffective July 14, 2019, the State of New York greatly expanded tenant protections with a large package of bills covering topics ranging from rent control to eviction restrictions to rent-to-own contracts for manufactured homes (MH). A majority of the law is aimed at protections for apartment renters in New York City and throughout the state.

Georgia Exempts Manufactured Home Retailers/Brokers from Mortgage Broker Licensing Effective July 1, 2019, Georgia House Bill 212 will affirmatively exempt retailers or retail brokers of manufactured or mobile homes from the state’s “mortgage broker” definition under Ga. Code Ann. § 7-1-1000. The bill specifically exempts manufactured housing retailers from mortgage broker licensing requirements, and the oversight that comes with licensure, provided the retailer or

Regulatory Reformation: Treasury’s First Recommendations for Improving Financial RegulationsOn February 3, 2017, President Donald Trump issued Executive Order 13772, which identified seven Core Principles by which his administration would regulate the U.S. financial system. The Executive Order also directed the U.S. Department of the Treasury to generate reports to identify any laws, treaties, regulations, guidance, reporting and recordkeeping requirements, and other government policies

Implementing a Compliant Successor in Interest Confirmation Process Will Pose Significant Challenges for Mortgage ServicersArguably the most significant element of the recent amendments to the existing mortgage servicing regulatory framework by the Consumer Financial Protection Bureau (CFPB) is the new structure that has been laid out for dealing with potential and confirmed successors in interest. Quite simply, fully complying with the new rule will require significant efforts, regardless of

CFPB’s New Loss Mitigation and Servicing Transfer Requirements Provide Clarity But Create Additional Compliance Challenges – Attend Part 4 of Our Webinar Series to Learn MoreA few short weeks after releasing a special edition Supervisory Highlights report that focused exclusively on mortgage servicing observations and, in particular, loss mitigation and servicing transfer issues, the CFPB released a 901-page set of amendments overhauling the existing mortgage servicing regulatory framework. A significant portion of those amendments relate to the same areas that

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Join us this Thursday, August 11, from 11:30 AM – 1:00 PM CST for the first webinar in our “CFPB Mortgage Servicing Amendments” series. Last week, the CFPB released its long-awaited amendments to the existing mortgage servicing rules in Regulations X and Z. The full release, which is 901 pages, details extensive changes to