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
May 6, 2016
Arbitration and the Common Man
Arthur Miller, the playwright who brought us Death of A Salesman, wrote an essay titled Tragedy and The Common Man. It opens, In this age few tragedies are written. It has often been held that the lack is due to … Continue reading
May 6, 2016 in Regulation | Permalink | No Comments
May 2, 2016
Nonbank Servicers Pose Risks for Homeowners
The Office of the Special Inspector General for the Troubled Asset Relief Program (SIGTARP) has released its Quarterly Report to Congress (April 27, 2016). The Report focuses on how nonbank servicers raise risks for homeowners participating in the Home Affordable Modification … Continue reading
May 2, 2016 in Regulation | Permalink | No Comments