On January 4, 2024, Connecticut Banking Commissioner Jorge L. Perez issued a temporary order to cease and desist against LoanSnap, Inc., ordering LoanSnap to cease and desist certain activities and notifying LoanSnap that its state mortgage lender license will be revoked
Financial Services Perspectives
Regulatory, compliance, and litigation developments in the financial services industry
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CFPB Issues Advisory Opinion Restricting Fees Charged for Consumer’s Requests for Account Information
In October 2023, the CFPB issued an advisory opinion titled, “Consumer Information Requests to Large Banks and Credit Unions.” The upshot of the advisory opinion is that covered financial institutions responding to consumer information requests under Section 1034(c) of the…
HUD OIG Reports HMBS Program Management Concerns
Consistent with its mission to safeguard against fraud, waste, and abuse, the Office of Inspector General (OIG) of the U.S. Department of Housing and Urban Development (HUD) recently announced concerns regarding Ginnie Mae’s management of its Home Equity Conversion Mortgage-Backed…
FHA Seeks Additional Feedback on New Loss Mitigation Option for Struggling Borrowers
On November 16, 2023, in response to comments received on a prior draft Mortgagee Letter (ML) related to a Proposed Payment Supplement Partial Claim, the Federal Housing Administration (FHA) published another draft ML titled “Payment Supplement.” The…
HUD Revises the HECM Program in Response to Changing Market Conditions
Last week, the Department of Housing and Urban Development (HUD) revised multiple regulations and requirements related to servicing Home Equity Conversion Mortgages (HECMs, more commonly known as “reverse mortgages”), with the goal of updating and streamlining the program to improve…
Creditors Should Review Their Use of Immigration Status When Accepting and Evaluating Applications
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…
CFPB Issues Additional Guidance on Use of AI in Credit Underwriting
On September 19, the Consumer Financial Protection Bureau (CFPB) issued Circular 2023-03, which provides guidance as to how lenders must explain denials of applications of credit when the underwriting is based on artificial intelligence (AI) or complex credit models.…
Questions to Consider as Regulators Increase Scrutiny of Medical Debt
Over the last year and a half, the Consumer Financial Protection Bureau (CFPB) has become increasingly interested in the origination, servicing, and collection of medical debt. The CFPB alone has published several pieces of industry guidance, 13 press releases concerning…
Questions to Consider as Regulators Increase Scrutiny of Medical Debt
Over the last year and a half, the Consumer Financial Protection Bureau (CFPB) has become increasingly interested in the origination, servicing, and collection of medical debt. The CFPB alone has published several pieces of industry guidance, 13 press releases concerning…
Questions to Consider as Regulators Increase Scrutiny of Medical Debt
Over the last year and a half, the Consumer Financial Protection Bureau (CFPB) has become increasingly interested in the origination, servicing, and collection of medical debt. The CFPB alone has published several pieces of industry guidance, 13 press releases concerning…