Archive: Predatory Lending
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Oct 23, 2009
No CommentsMore, or Less Consumer Regulation? More!
By Edward B. Kramer, Executive VP, Regulatory Programs As we all know by now, the House Financial Services Committee voted 39 to 29 on Thursday to approve legislation to create a consumer financial protection agency, a key priority in the Obama administration’s regulatory reform plan. The bill would remove from the federal banking and thrift agencies...
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Sep 21, 2009
No CommentsUptick in Federal Bank Regulator Enforcement on the Way…
by Edward B. Kramer, Executive VP, Regulatory Programs At last week’s MBA Regulatory Compliance Conference, a prominent Washington attorney noted that there would be a major uptick in federal bank regulator enforcement, both as part of usual examination process and as special inquiries. Jeff Naimon of BuckleySandler said there would be a strong focus on...
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Jul 21, 2009
No CommentsFederal Reserve Doing Targeted Exams of Mortgage Units
by Edward B. Kramer, Executive VP, Regulatory Programs There a significant consumer protection development that is impacting the mortgage banking subsidiaries of bank holding companies, according to an article in the July 21, 2009 edition of National Mortgage News. The Federal Reserve Board is expanding its consumer protection role by performing targeted exams of mortgage...
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Jul 09, 2009
No CommentsHigher Priced Mortgages – Freddie Mac Guidance
Freddie Mac has issued their guidance about purchasing higher priced mortgages starting October 1st. Their guidance may have answered our questions about how to originate 5 year balloons and ARMS. For it appears they will not purchase these loans. This new wrinkle makes it even more important to test your loans early and often. If the loan...
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Jun 10, 2009
No CommentsOverheard at the ABA Compliance Conference
by Edward B. Kramer, Executive VP, Regulatory Programs Below are a few very-telling snippets I heard from the Federal bank regulators while attending the ABA Regulatory Compliance Conference in Florida: Be aware of the fair lending implications of your credit tightening in the current environment. Remember that fair lending/predatory lending violations will be factored into...
