A CID recipient could not disclose its receipt of such a demand to counterparties under financing agreements, loan sales agreements, and purchase and sale agreements, which routinely require such disclosures.
Earlier in the year, the IRS said it planned to strengthen the protections for e-services accounts by requiring a stronger identity verification process for existing and new accounts.
The ICBA noted that community banks have invested heavily in complying with the disclosure rules, but the complexity of the requirements has made it inevitable that some will be found non-compliant.
Last week’s closely-watched appeals court ruling in the wrangling between PHH Mortgage and the Consumer Financial Protection Bureau over Section 8 of the Real Estate Settlement Procedures Act is being widely viewed by many as a clipping of the agency’s wings.
Some good news for default servicing: For all the loans that are out there, there will always be excessive debt, illness, divorce, unemployment, or some other disruptive factor, noted one expert.
Further, the decision opens up prior actions taken by the bureau to potential challenges to the validity of past guidance, consent orders, fines and rules.
The traditional interpretation of Section 8 of the Real Estate Settlement Procedures Act that the mortgage industry has relied on for decades was vindicated this week when ...