The Federal Reserve will slightly decrease the amount of its monthly purchases of agency mortgage-backed securities but agency MBS issuance might decline by even more than the Fed's planned taper.
A BuckleySandler lawyer reached into Zen lore to make his point. “If a tree falls in the forest and no one hears it, does it make a sound?” he asked. Similarly, “Starting in 2014: If a lender complies with ATR/QM but cannot evidence it, has the lender complied?”
“There has been significant industry confusion concerning the extent to which affiliate fees are included in the points-and-fees calculation, particularly when only a portion of a fee is retained by an affiliate,” the Mortgage Bankers Association said.
“The CFPB’s treatment of balloon loans was a step in the right direction, and demonstrated recognition of the unique nature of community banking and a different approach to regulating them,” the CSBS says in a new white paper.
In its fundraising pitch for its lawsuit against the CFPB, the NAIHP states that, “Neither Congress nor the executive branch holds any authority to curb CFPB’s behavior. Only the courts can stop them.”
The Consumer Financial Protection Bureau, which inherited RESPA enforcement from HUD, has been leaning on this test in such enforcement actions of its own.
Standard & Poor’s recently published an updated estimate of likely losses stemming from mortgage-related litigation, finding that banks face future costs of $56.5 billion to $104 billion.