Financial Institutions Regulatory
Compensation and Compliance Matters: Rose-Tinted Cost Estimates Will Have Regulators Seeing Red
Overly optimistic assumptions that can create false impressions for borrowers can easily rise to the level of an unfair and…
Read MoreCompensation and Compliance Matters: Why Expanded QM Exemption for Small Lenders Doesn’t Go Far Enough
The Consumer Financial Protection Bureau’s recent change to the definition of small creditor, while seemingly poised to make room for…
Read MoreCompensation and Compliance Matters: Home Mortgage Disclosure Act Data Disclosures Pose Risks for Lenders and Borrowers
When the Consumer Financial Protection Bureau issued its long-awaited final Home Mortgage Disclosure Act rule last week the amount of…
Read MoreCompensation and Compliance Matters: Why MSAs Are More Trouble Than They’re Worth
The guidance that the Consumer Financial Protection Bureau issued recently on marketing services agreements is fuzzy, at best. Because the…
Read MoreCompensation and Compliance Matters: Thanks for the Grace Period But…
The Consumer Financial Protection Bureau announced Tuesday that it will support a hold harmless period for banks to get into…
Read MoreCompensation and Compliance Matters: Fair Lending Lawsuit Could Affect Disparate Impact
The city of Miami was recently found to have standing to sue lenders under the Fair Housing Act in a…
Read MoreCompensation and Compliance Matters: Lenders Better Have a Good Reason for TRID Estimate Change
What exactly is an “extraordinary” or “other unexpected event” under the TILA-RESPA integrated disclosure rules? The new definition of “changed…
Read MoreCompensation and Compliance Matters: Loan Officer Comp Rules Obscured by ‘Unforeseeable Circumstances’
Under the current loan officer compensation rules, one point that isn’t completely clear is whether a lender may charge LOs…
Read MoreCompensation and Compliance Matters: Three Regulators Are Scarier than One
In the latest example of exemplary coordination between other federal agencies and various states, the Consumer Financial Protection Bureau, the…
Read MoreCompensation and Compliance Matters: Here’s One Thing the CFPB Gets Right
There are many concerning aspects of the Consumer Financial Protection Bureau’s methods, not the least of which include its proclivity…
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