October 14, 2014
Reiss on The FHFA’s Common Securitization Platform
I have submitted my response to the FHFA’s Request for Input on the Proposed Single Security Structure. The abstract for my response, The FHFA’s Proposed Single Security Structure, reads, The Federal Housing Finance Agency (FHFA) has posted a Request for … Continue reading
October 14, 2014 in Regulation | Permalink | No Comments
October 10, 2014
Dodd-Frank Mortgage Rules Readiness Guide
The CFPB issued Version 3.0 of its 2014 CFPB Dodd-Frank Mortgage Rules Readiness Guide “to help financial institutions come into and maintain compliance with the new mortgage rules outlined in Part I of this Guide. . . .. This Guide … Continue reading
October 10, 2014 in Regulation | Permalink | No Comments
October 9, 2014
A Framework For Housing Finance
The Government Accountability Office has released Housing Finance System: A Framework for Assessing Potential Changes. The GAO writes, To help policymakers assess various proposals for changing the single-family housing finance system and consider ways in which the system could be … Continue reading
October 9, 2014 in Regulation | Permalink | No Comments
October 6, 2014
Are the FHA’s Losses Heartbreaking?
The Inspector General of the Department of of Housing and Urban Development issued an audit of FHA’s Loss Mitigation Program (2014-KC-0004). The Office of the Inspector General (the OIG) did the audit because of its “concern that FHA might have incurred … Continue reading
October 6, 2014 in Regulation | Permalink | No Comments
September 25, 2014
How Much Did the FHA Cost Us?
Until the financial crisis hit, the Federal Housing Administration has never required budgetary support for its mortgage insurance programs. When it received a $1.7 billion infusion from the Treasury, it was seen as a sad day in the FHA’s long … Continue reading
September 25, 2014 in Regulation | Permalink | No Comments
September 19, 2014
Performance-Based Consumer Law
Lauren Willis has posted Performance-Based Consumer Law to SSRN. This article makes the case for recognizing performance-based regulation as a distinct tool in the consumer-law regulatory toolbox and for employing this tool broadly. Performance-based consumer law has the potential to … Continue reading
September 19, 2014 in Regulation | Permalink | No Comments
September 18, 2014
Frannie Reps and Warranties Crisis Brewing
The Inspector General of the Federal Housing Finance Agency released an audit, FHFA’s Representation and Warranty Framework. Reps and warranties are a risk-shifting device that sophisticated commercial parties use in transactions. If a party makes a representation or warranty that … Continue reading
September 18, 2014 in Regulation | Permalink | No Comments
