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Jonathan Kolodziej represents all types of consumer financial service providers in regulatory compliance, examination and enforcement matters. Through this work, he has assisted bank and non-bank mortgage servicers, mortgage originators, debt collectors, depository institutions, credit card issuers, small dollar lenders, reverse mortgage companies, investment firms, and various industry trade associations.

Within approximately 48 hours, starting on the evening of Friday, February 7, 2025, the trajectory of the Consumer Financial Protection Bureau (CFPB) was significantly altered. Among other things, a new acting director was installed, a more comprehensive internal pause – one that now explicitly covers supervision, examination, and enforcement activities – was put in place

On December 17, 2024, amid a flurry of activity by the Consumer Financial Protection Bureau (CFPB), the agency released an Issue Spotlight discussing “problems with mortgage companies” that homeowners face “after divorce or [the] death of a loved one.” The report relies on consumer complaints that have been submitted through the CFPB’s complaint portal to

On Thursday, November 21, 2024, the Consumer Financial Protection Bureau (CFPB) published a final rule that will soon provide it with supervisory authority over large companies in the general-use digital consumer payment applications market. This rule will become effective 30 days after it is published in the Federal Register and will subject large participants in

On July 10, 2024, the Consumer Financial Protection Bureau (CFPB) released a proposal to amend the existing mortgage servicing rules in Regulation X. The substance of the proposal has attracted a lot of attention and deservedly so. If enacted, the proposed rule would completely overhaul the default servicing framework in Regulation X and institute mandatory

On Wednesday, July 10, 2024, the Consumer Financial Protection Bureau (CFPB) released its long-awaited and much anticipated proposal to amend Regulation X. As expected, the proposal focuses primarily on default servicing requirements and would impose an entirely new framework for regulating how loss mitigation is handled in the mortgage servicing industry. Other topics are

In a consent order with a reverse mortgage servicer on June 18, 2024, the Consumer Financial Protection Bureau (CFPB) made the argument that failing to effectively service loans is abusive. The groundwork for this line of thinking was laid out by the current CFPB administration through various statements and guidance documents, but the public order

While the Spring 2024 Supervisory Highlights report issued by the Consumer Financial Protection Bureau (CFPB) largely covered loss mitigation deficiencies and fee practices — issues that are regulatory priorities and, therefore, top of mind for mortgage servicers — two potentially under-the-radar findings outlined in the report are actually noteworthy and merit further analysis. First, in

In an October 2023 advisory opinion, the Consumer Financial Protection Bureau (CFPB) put large banks and credit unions on notice that the use of chatbots and other technologies could increase the risk of violating federal law if those services are ineffective. As we have previously written about, the CFPB’s advisory opinion interprets Section

On October 12, the Consumer Financial Protection Bureau (CFPB) and Department of Justice (DOJ) issued a joint statement emphasizing the risk associated with considering an applicant’s immigration status when making credit decisions. Specifically, the CFPB and DOJ emphasized that creditors should carefully consider how they use immigration status when accepting and evaluating applications and should