November 29, 2013
Dirty REMICs: A Debate
Brad, Joshua Stein and I have posted Dirt Lawyers and Dirty REMICs: A Debate to SSRN (also on BePress). Brad and I had posted our side of the debate at various points, but the entire back and forth is contained … Continue reading
November 29, 2013 in CFPB | Permalink | No Comments
November 4, 2013
Balancing Consumer Protection and Access to Credit
S&P posted U.S. RMBS Roundtable: Originators, Aggregators, and Counsel Discuss New Qualified Mortgage Rules. In summarizing the roundtable, S&P notes that The ability-to-repay rule, ostensibly to prevent defaults and another housing crisis, is still very much open to interpretation. To … Continue reading
November 4, 2013 in CFPB | Permalink | No Comments
November 1, 2013
Measuring Progress at the CFPB
The Bipartisan Policy Center issued a white paper, The Consumer Financial Protection Bureau: Measuring the Progress of a New Agency: This paper measures the agency’s actions against its mandate. It analyzes the start-up and operational challenges the Bureau has faced … Continue reading
November 1, 2013 in CFPB | Permalink | No Comments
October 22, 2013
Private Capital and the Mortgage Markets
The American Securitization Forum recently wrote to the Federal Housing Finance Agency to argue for at least a small reduction in the size of the loans that Fannie and Freddie can guaranty. While this makes sense to me, it is … Continue reading
October 22, 2013 in CFPB | Permalink | No Comments
October 18, 2013
Making Sense of Finance Charges
The Consumer Financial Protection Bureau has a very helpful Finance Charge Chart (page 13) in its Truth In Lending Act examination procedure manual. The manual is “intended for use by CFPB examiners in examining the mortgage companies and other financial … Continue reading
October 18, 2013 in CFPB | Permalink | No Comments
October 11, 2013
Fightin’ Words on Consumer Complaints
Deloitte has issued a report, CFPB’s Consumer Complaint Database: Analysis Reveals Valuable Insights, that provides valuable — but superficial insights — into the CFPB’s massive database of consumer complaints. Deloitte’s main insights are Troubled mortgages are behind the majority of … Continue reading
October 11, 2013 in CFPB | Permalink | No Comments
October 1, 2013
Financial Education: Miles to Go Before We Can Sleep Easily
The CFPB has posted Financial Empowerment Training for Social Service Programs: A Scan of Community-Based Initiatives. The report opens well, with Gail Hillebrand, the Associate Director for Consumer Education and Engagement, noting that Consumers need four things to be financially … Continue reading
October 1, 2013 in CFPB | Permalink | No Comments
