Is it a grace period or not? That is the big question surrounding the very recent CFPB letter on post TRID implementation enforcement actions. Although CFPB has announced it will be sensitive to lenders that make a “good faith” effort to comply with the new rules, they do not go as far as to say there will be no enforcement…
Provident Funding Associates, a major California-based wholesale lender, recently settled with the Consumer Financial Protection Bureau and the Department of Justice to the tune of $9 million. The settlement was not for any violations made by Provident, but for lending discrimination by Brokers who originated loans for Provident. The discrimination came about in the form of higher rates being charged to…
The Consumer Financial Protection Bureau issued Bulletin 2015-02 (Section 8 HCV) advising lenders of the pitfalls of excluding a consumer’s income derived from assistance received under the “Section 8 Housing Choice Voucher Homeownership Program” (now there’s a mouthful). They also highlighted information on their website for consumers that it is illegal for lenders not to use this voucher income (CFPB…
Could redlining in mortgage lending still exist? According to CFPB and the Department of Justice, it sure does, and they are out to do something about it (Redlining). The CFPB and DOJ are putting out the word to all mortgage lenders that they believe redlining definitely still exists and that they are working closely together to identify and correct any…
We all have heard the old saying, “If it looks like a duck, walks like a duck and quacks like a duck; it must be a duck”. Well, this also holds true for mortgage marketing service agreements (MSA). CFPB is taking a long hard look at entities with such agreements and a tough stand on enforcement for what they determine…
Lenders – are you utilizing Service Providers (or Third Party Vendors) to assist you in your Operations? If so – are you properly monitoring the associated risks in employing such Firms? Read on! The Consumer Financial Protection Bureau (CFPB) fully expects supervised banks and non-banks to properly manage the associated risks with employing service providers (or third party vendors). These…
