Mortgage Loan Originators

Recent Updates Concerning the Home Mortgage Disclosure ActThe Consumer Financial Protection Bureau (CFPB) has been busy over the last few months laying out what appears to be a broad regulatory agenda. As discussed in this blog, the Bureau has issued an industry notice emphasizing industry preparedness related to COVID-19 forbearance plans, issued proposed COVID-19-related amendments to the Mortgage Servicing Rules, suggested

FEMA Releases Flood Insurance Rating Methodology Under Risk Rating 2.0On April 1, 2021, FEMA released its highly anticipated flood insurance rating methodology, Risk Rating 2.0-Equity in Action.

FEMA first announced “Risk Rating 2.0-Equity in Action” in March 2019 as an effort to improve flood maps and offer rates that are fair, easy to understand, and more aligned with a property’s unique flood risks. The

On March 31, 2021, the Consumer Financial Protection Bureau (CFPB) rescinded seven recent policy statements and one bulletin in an effort to ensure compliance with consumer protection laws and reinforce its supervisory and enforcement authority. These rescissions are effective April 1, 2021.

The policy statements, which were issued between March 26 through June 3, 2020,

FHA Clarifies That DACA Classified Residents Are Permitted to Apply for FHA-Insured MortgagesOn January 20, 2021, the U.S. Department of Housing and Urban Development (HUD) released guidance clarifying its definition of the term “lawful residency.” Under the updated guidance, HUD makes clear that individuals classified under the Deferred Action for Childhood Arrivals (DACA) program with the U.S. Citizenship and Immigration Service (USCIS) and are legally permitted to

New York DFS Turns Up the Heat with Climate Change BulletinThe New York Department of Financial Services (DFS) has issued a bulletin on climate change and financial risks to the financial institutions and insurance companies it supervises regarding the impact of climate change on those institutions. DFS asserts that “[f]inancial risks from climate change are unprecedented” and notes a warning from the Bank for International

FHA Posts Proposed Rule Permitting Acceptance of Private Flood InsuranceOn November 10, 2020, the U.S. Department of Housing and Urban Development (HUD)  released a proposed amendment to Federal Housing Administration (FHA) regulations that would allow lenders to accept private flood insurance policies on FHA-insured properties located in Special Flood Hazard Areas. HUD will accept comments for 60 days following the date the proposed rule,

Federal District Court Stays Effective Date and Enjoins Enforcement of HUD’s Final Rule on the Fair Housing Act’s Disparate Impact StandardOn October 24, 2020, the U.S. Department of Housing and Urban Development’s (HUD) final rule on the implementation of the Fair Housing Act’s disparate impact standard was scheduled to become effective. That effective date was short lived: on October 25, 2020, the U.S. District Court for the District of Massachusetts entered a preliminary injunction staying

HUD Issues Final Rule on the Fair Housing Act’s Disparate Impact StandardOn September 3, 2020, the U.S. Department of Housing and Urban Development (HUD) issued its final rule on the implementation of the Fair Housing Act’s disparate impact standard. The Fair Housing Act (FHA) prohibits discrimination in many housing-related activities on the basis of race, color, religion, sex, disability, familial status, and national origin. For

Federal Reserve Implements Aggressive Liquidity Campaign as Growing Corporate Debt Threatens to Exacerbate COVID-19 Economic TollIn response to the recent COVID-19 outbreak, Congress recently approved a $2 trillion stimulus package in an attempt to offset the potentially disastrous economic effects of COVID-19. Meanwhile, central banks are implementing increasingly drastic measures aimed at preserving the availability of capital during the looming recession, which appears increasingly imminent as the global economy remains

Federal Regulatory Agencies Offer Interagency Statement Regarding COVID-19-Related Loan Modifications and Status ReportingThe Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency, the Consumer Financial Protection Bureau, and the Conference of State Bank Supervisors issued an Interagency Statement on March 22 urging regulated financial institutions to work with borrowers affected