July 6, 2016
Violations of Law and Consumer Harm
The Federal Financial Institutions Examination Council (FFIEC) issued a notice and request for comment regarding the Uniform Interagency Consumer Compliance Rating System (CC Rating System). My comment letter reads as follows: The Federal Financial Institutions Examination Council (FFIEC) issued a notice and request for comment regarding … Continue reading
July 6, 2016 in Regulation | Permalink | No Comments
July 5, 2016
Dems Favor Land Use Reform
The Democratic Party has released its draft 2016 Policy Platform. Its housing platform follows in its entirety. I find the highlighted clause particularly intriguing and discuss it below. Where Donald Trump rooted for the housing crisis, Democrats will continue to fight … Continue reading
July 5, 2016 in Regulation | Permalink | No Comments
June 8, 2016
What If . . . Fannie and Freddie Imploded?
So, I was spending some quality time with the Federal Housing Finance Agency Office of the Inspector General’s most recent Semiannual Report to the Congress. The Federal Housing Finance Agency (FHFA) is the regulator of Fannie and Freddie as well … Continue reading
June 8, 2016 in Regulation | Permalink | No Comments
June 6, 2016
What Are Mortgage Borrowers Thinking?
The Consumer Financial Protection Bureau (CFPB) and the Federal Housing Finance Agency (FHFA) have released A Profile of 2013 Mortgage Borrowers: Statistics from the National Survey of Mortgage Originations. While sounding dull and perhaps a bit dated, this document is actually … Continue reading
June 6, 2016 in Regulation | Permalink | No Comments
June 2, 2016
Ensuring Sustainable Homeownership
My short article, Ensuring That Homeownership Is Sustainable, was just published in the Westlaw Journal, Bank & Lender Liability. It opens, The Federal Housing Administration has suffered as a result of many of the same unrealistic underwriting assumptions that led to problems … Continue reading
June 2, 2016 in Regulation | Permalink | No Comments
May 26, 2016
Unruly Arbitration
I had blogged earlier about the Consumer Financial Protection Bureau’s proposed rule regarding arbitration. Along with 209 other law professors, I submitted a comment letter regarding it. The letter opens, We write to strongly support proposed regulation CFPB-2016-0020, RIN 3170-AA51. … Continue reading
May 26, 2016 in Regulation | Permalink | No Comments
May 16, 2016
Uses & Abuses of Online Marketplace Lending
The Department of the Treasury has issued a report, Opportunities and Challenges in Online Marketplace Lending. Online marketplace lending is still in its early stages, so it is great that regulators are paying attention to it before it has fully matured. … Continue reading
May 16, 2016 in Regulation | Permalink | No Comments
