The Consumer Financial Protection Bureau (CFPB) has offered its new mortgage servicing rule for public inspection today, meaning it is scheduled to be published in the Federal Register on October 19, 2016. The CFPB informally released the rule on its website in August.
The effective date of the rule is tied to its publication date,
If you think the shadow of the Consumer Financial Protection Bureau (“CFPB”) is hiding behind a tree, you may well be right. On July 7th, the CFPB posted a Request for Information (“RFI”) on the federal government contracts website, called FedBizOpps.gov, in which it “pre-solicited” vendor capabilities to develop an automated technology solution for nonbank financial institutions to register with the CFPB. It noted that such a potential registration system “might also be used to collect financial and operational data as well as organizational structure data.” In other words, in the name of supervision, the CFPB might condition your future ability to offer goods and services on your advance registration and satisfaction of ongoing reporting requirements.
Continue Reading Papers Please: CFPB Advances Plans to Register Nonbank Financial Services Providers
Tomorrow, September 13, 2016, Mayer Brown partner Jeff Taft will be speaking at the inaugural Marketplace Lending Policy Summit in Washington, D.C. Jeff will be on a panel covering “Hot Legal Topics in Marketplace Lending.”
David Beam, Keisha Whitehall-Wolfe, and Eric Mitzenmacher also will be attending the conference.
On September 12, 2016, the Nationwide Multistate Licensing System (“NMLS” or “the System”) will begin receiving and tracking Electronic Surety Bonds (“ESB”). In an unprecedented departure from the traditional uploading of a copy of a surety bond document to the applicant’s or licensee’s record followed by the delivery of the paper bond to the state, regulators in Idaho, Indiana, Iowa, Massachusetts, Texas, Vermont, Washington, and Wisconsin have publicly announced the adoption of ESB in 2016 for several license types. This is the first group of states to “bond on line,” but all states are expected to have a common bond process through the NMLS.
Continue Reading Dawn of the Bond – New NMLS Electronic Surety Bond*
Last week the American Association of Residential Mortgage Regulators (AARMR) hosted its 27th annual regulatory conference in Tampa, Florida. Over 300 attendees gathered to exchange information relating to the licensing, supervision, and regulation of the residential mortgage industry. Here are some of the highlights from the conference:
Continue Reading Reflections on AARMR 2016 from a Former Regulator