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
May 13, 2016
Affirmatively Furthering Neighborhood Choice
Jim Kelly has posted Affirmatively Furthering Neighborhood Choice: Vacant Property Strategies and Fair Housing to SSRN (forthcoming in the University of Memphis Law Review). He writes, With the Supreme Court’s Inclusive Cmtys. Project decision in June 2015 and the Obama Administration’s adoption, … Continue reading
May 13, 2016 in Regulation | Permalink | No Comments
May 11, 2016
Consumer Protection’s Holy Grail
The Federal Financial Institutions Examination Council (FFIEC) has issued a notice and request for comment regarding the Uniform Interagency Consumer Compliance Rating System (the CC Rating System). The FFIEC’s six members represent the Federal Reserve Board, Federal Deposit Insurance Corporation, National Credit … Continue reading
May 11, 2016 in Regulation | Permalink | No Comments