On October 1, 2025, the interagency final rule implementing quality control standards for automated valuation models (“AVMs”) became effective. The rule requires the adoption and maintenance of policies, practices, procedures, and control systems for the use of AVMs
Consumer Financial Services Review
News and Analysis Related to Consumer Financial Services, Litigation, and Enforcement
The Consumer Financial Services Review, published by Mayer Brown, focuses on legal developments and regulatory issues affecting consumer financial services. It covers topics such as state and federal lending laws, interest rate exportation, licensing requirements for lenders and loan arrangers, mortgage origination standards including automated valuation models, and consumer protection statutes like the California CARS Act. The blog also addresses regulatory proposals and rulemakings impacting reverse mortgage programs and secondary market issuers. It provides updates on litigation, compliance challenges, and legislative changes relevant to banks, fintech companies, and other financial institutions engaged in consumer lending and credit transactions.
Latest from Consumer Financial Services Review - Page 2
New California CARS Act
By Kris D. Kully & Joy Tsai
The new California Combating Auto Retail Scams (CARS) Act, which Governor Newsom signed on October 7, 2025, mirrors the thwarted efforts of the Federal Trade Commission (“FTC”) to address concerns about unfair or deceptive acts or practices among motor…
HUD Seeks Input on Reverse Mortgage Programs
On October 2, 2025, HUD, through FHA and Ginnie Mae, issued a Request for Information (RFI) seeking public input on the current and future roles of the Home Equity Conversion Mortgage (HECM) and HECM Mortgage-Backed Securities (HMBS) programs. Stakeholders are…
SEC Seeks Input on Modernizing RMBS Disclosure Requirements and Enhancements to ABS Registration to Revitalize Public Securitization Market
The Securities and Exchange Commission (SEC) has published a concept release inviting public comment on potential reforms to disclosure requirements for residential mortgage-backed securities (RMBS) in the registered asset-backed securities (ABS) market. The initiative aims to address longstanding concerns that…
Illinois Proposes Regulations Governing Shared Appreciation Agreements
Illinois continues to move forward in regulating “shared appreciation agreements.” On August 15, 2025, the Illinois Department of Financial and Professional Regulation proposed regulations implementing the Residential Mortgage License Act of 1987 to govern “shared appreciation agreements.” The term “shared…
Massachusetts AG Settles Fair Lending Action Based Upon AI Underwriting Model
California Enacts Servicing Requirements for Subordinate Residential Mortgages
On June 30, California Governor Newsom signed Assembly Bill No. 130 (“AB130” or the “Bill”). Effective immediately, the Bill added a new section to the California Civil Code to codify that certain actions constitute unlawful practices when taken by a…
Court Declines to Allow CFPB to Vacate Townstone Settlement
On June 12, 2025, Judge Valderrama of the federal district court for the Northern District of Illinois denied the joint motion to vacate the stipulated final judgment reached between the Consumer Financial Protection Bureau (“CFPB”) and Townstone Financial, Inc., in…
Update on Maryland Mortgage Licensing Guidance: Governor Moore Signs Law Exempting Passive Trusts
Maryland’s secondary mortgage market has been in turmoil since a disruptive 2024 court decision held that a purchaser of mortgage loans inherits the original lender’s obligations—including the obligation to obtain a Maryland Mortgage Lender license. Secondary market investors that acquire…
Buckle Up for New Regulatory Activity in Motor Vehicle Sales and Financing
Although the Fifth Circuit Court of Appeals vacated the Federal Trade Commission’s (“FTC”) Combating Auto Retail Scams Trade Regulation Rule (“CARS Rule”) on January 27, 2025, the FTC and state attorneys general continue to target the auto sales and lending…