The U.S. Department of Housing and Urban Development (HUD) recently took concrete steps toward addressing industry concerns and uncertainty related to the Claims Without Conveyance of Title (CWCOT) foreclosure bidding process. Ultimately, mortgagees still must bid the Commissioner’s Adjusted Fair Market Value (CAFMV) at foreclosure sale to file a CWCOT claim with HUD, but pursuant
Two recent guilty pleas by former TD Bank employees — Oscar Marcel Nunez-Flores and Wilfredo Aquino — are a timely reminder that insider-enabled money laundering can defeat control frameworks if banks do not actively design for, detect, and deter employee misconduct. These cases come on the heels of TD Bank’s October 2024 criminal guilty plea
In Florida’s 2026 legislative session, both chambers will consider bills that would impose strict requirements for caller identification on businesses. The bills target both telecommunications companies and the callers. While the legislation is presumably meant to target telephone scams and robocalls, its broad blocking mandates and authentication requirements would impact any company that places calls
New York has taken a significant step toward reshaping its consumer and market-protection framework with the enactment of the Fostering Affordability and Integrity through Reasonable (FAIR) Business Practices Act. The newly signed law amends Article 22-A of the General Business Law, expanding the scope of conduct prohibited under GBL § 349 and clarifying how
Russ Vought’s CFPB has been busier over the past two weeks, but not because of increased enforcement or supervision efforts. Instead, recent actions indicate that the administration intends to keep Vought in the acting director position so he can shutter or even more substantially shrink the CFPB and the laws it enforces. But the CFPB’s
On November 13, 2025, the Consumer Financial Protection Bureau (CFPB) released a Notice of Proposed Rulemaking (NPRM) amending Regulation B – the regulation implementing the Equal Credit Opportunity Act (ECOA). The proposed rule addresses three principal areas: (1) it clarifies that ECOA does not authorize disparate-impact liability; (2) it further defines “discouragement” under 12 CFR
Speaking at the Clearing House’s annual conference, Comptroller of the Currency Jonathan Gould assured industry leaders that the agency remains steadfast in defending federal preemption under the National Bank Act. Gould’s comments come in the wake of recent federal appellate court decisions in the Ninth and First circuits, which challenged the OCC’s stance by finding
In the wild new world of TCPA litigation following the end of binding deference to the Federal Communications Commission (FCC), one of the more salient questions is whether the Do-Not-Call (DNC) Registry’s protections extend to the sending of text messages. Florida finds itself at ground zero for this debate after three different federal district courts
Two recent developments signal that momentum is building in Washington to recalibrate Bank Secrecy Act (BSA) reporting to produce higher‑value intelligence with less compliance friction. First, on October 9, 2025, the Financial Crimes Enforcement Network (FinCEN) and the federal banking regulators issued joint guidance in the form of Suspicious Activity Report (SAR) FAQs clarifying several
Home equity products enable homeowners to unlock the value of their homes through a variety of financing contracts. Each product has distinct features, benefits, and risks. In this post, we compare and contrast common home equity products, including home equity lines of credit (HELOC), closed-end home equity loans (HEL), reverse mortgages, and home equity agreements