On September 21, 2018, the Department of Housing and Urban Development (“HUD”)’s Office of Inspector General (“OIG”) completed a review of HUD’s partial claims program. In many ways, the title of the OIG audit report, “HUD Did Not Have Adequate Controls To Ensure That Partial Claim Notes for FHA Loans Were Properly Tracked for
CFPB Student Loan Ombudsman Abruptly Resigns in Protest
In another move reflecting the Consumer Financial Protection Bureau’s (CFPB) shifting focus on student lending, the CFPB’s Student Loan Ombudsman announced his resignation on August 27, 2018. In his resignation letter, Seth Frotman, who served as the Student Loan Ombudsman for the past three years, criticized reforms implemented by the CFPB’s current leadership and
Providing Banking Services to the Legal Marijuana Industry: Mitigating Risks to Maximize Potential Rewards
Since 1996, when California became the first state to legalize marijuana (at the time, for medicinal purposes only), 28 additional states and the District of Columbia have legalized marijuana to some extent. Public support for legalization continues to rise as more and more jurisdictions loosen their marijuana laws, with 64 percent of Americans in favor
Federal Reserve Proposes Modifications to Its Supervisory Appeals Process and Ombudsman Policy
On Tuesday, February 27, 2018, the Federal Reserve proposed to modify its guidelines and processes that institutions may rely upon to appeal an adverse material supervisory determination. The proposal also seeks to modify the Federal Reserve’s policy for its Ombudsman. Comments regarding the proposals will be accepted through April 30, 2018.
Appeals Process
The Federal