As previously reported, unable to agree on long-term reforms for the National Flood Insurance Program (NFIP), at the end of last year Congress extended the NFIP through September 30, 2020, which is the end of the current federal government fiscal year. With that date looming, in a letter to majority and minority leaders in
Mortgages
CFPB Summer 2020 Supervisory Highlights looks at consumer reporting, debt collection, deposits, fair lending, mortgage servicing, and payday lending
The CFPB has released the Summer 2020 edition of its Supervisory Highlights. The report discusses the Bureau’s examinations in the areas of consumer reporting, debt collection, deposits, fair lending, mortgage servicing, and payday lending that were completed between September 2019 and December 2019.
Key findings are described below.
Consumer reporting. CFPB examiners found:…
CFPB Issues Additional Consent Orders for False and Misleading Mortgage Advertising
By Amanda E. Phillips & Richard J. Andreano, Jr. on
Since late July, the CFPB has issued seven consent orders against mortgage companies in which the CFPB asserts that the companies engaged in false and misleading advertising to service members and veterans. This advertising focus is familiar and similar to a series of enforcement actions by the CFPB in December 2016 in which it asserted…
CFPB Issues Additional Consent Order for False and Misleading Mortgage Advertising
By Amanda E. Phillips & Richard J. Andreano, Jr. on
On August 21, 2020, the CFPB announced the issuance of a consent order against Go Direct Lenders, Inc. (Go Direct). This follows consent orders discussed in a previous blog post, that were announced on July 24, 2020 against Sovereign Lending Group, Inc. (Sovereign) and Prime Choice Funding, Inc. (Prime Choice). The CFPB indicated in…
CFPB Announces Release of HMDA Guides for 2021 Data
By Richard J. Andreano, Jr. on
On August 21, 2020, the CFPB announced the release of the Home Mortgage Disclosure Act (HMDA) Filing Instruction Guide (FIG) for data that must be collected in 2021 and reported in 2022. The CFPB also announced the release of the Supplemental Guide for Quarterly Filers that also applies to 2021 data. HMDA requires the quarterly…
CFPB Issues Promised Seasoned Qualified Mortgage Loan Proposal
By Richard J. Andreano, Jr. on
As promised by the CFPB when it issued two Regulation Z ability to repay rule qualified mortgage (QM) loan proposals in June 2020, the CFPB recently issued a proposal to provide for a new seasoned QM loan. Comments will be due 30 days after the proposal is published in the Federal Register.
The CFPB…
Fannie Mae and Freddie Mac announce adverse market LLPA
By John V. Levonick on
Posted in Mortgages, Regulatory and Enforcement
On August 12, 2020, Fannie Mae and Freddie Mac announced that the cost to originate and to deliver single family limited cash out refinances and cash out refinance mortgage loans would increase by one half of one percent (0.500%), or 50 bps, as a loan level pricing adjustment (LLPA). Fannie Mae Lender Letter (LL-2020-12) states…
CFPB Issues Consent Orders for False and Misleading Advertising for VA Mortgages
By Amanda E. Phillips & Richard J. Andreano, Jr. on
On July 24, 2020, the CFPB announced the issuance of consent orders against Sovereign Lending Group, Inc. (Sovereign) and Prime Choice Funding, Inc. (Prime Choice). The CFPB indicated in their announcement that these consent orders originated from a number of investigations by the CFPB into companies allegedly using deceptive direct mail campaigns to advertise VA…
CFPB Updates HMDA FAQs
By Richard J. Andreano, Jr. on
The CFPB recently updated its Home Mortgage Disclosure Act (HMDA) FAQs to add two items regarding multiple data points.
In one FAQ, the CFPB confirms that a lender must report the credit score, debt-to-income (DTI) ratio and combined loan-to-value (CLTV) ratio if they were a factor relied on in making a credit decision, even if…
CFPB Files First Ever Redlining Complaint Against a Non-Bank Mortgage Lender
By Richard J. Andreano, Jr. on
On July 15, 2020, the CPFB filed a complaint in federal court against Townstone Financial, Inc. (Townstone) representing the first ever redlining complaint against a non-bank mortgage lender. The complaint is brought under the Equal Credit Opportunity Act (ECOA) and Consumer Financial Protection Act (CFPA), but not the Fair Housing Act (FHA). (The U.S. Department…