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Joseph Reilly

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Financial services companies depend on Joe for all aspects of their regulatory and compliance needs. Drawing from two decades of experience in the sector, he provides actionable guidance in a complex and evolving landscape.

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On June 29, the Federal Financial Institutions Examination Council (FFIEC) announced the availability of data on 2022 mortgage lending transactions reported under the Home Mortgage Disclosure Act (HMDA) by U.S. financial institutions, including banks, savings associations, credit unions, and mortgage companies. The Snapshot National Loan-Level Dataset contains the national HMDA datasets as of May 1, 2023. In March 2023, the FFIEC had made available Loan/Application Registers (LARs) for each HMDA filer of 2022 data, as well as a combined dataset for all filers, modified to protect borrower privacy.

Key observations about the 2022 HMDA data include the following:

As recently discussed on our podcast here, section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act) amended the Equal Credit Opportunity Act (ECOA) to require lenders to collect information about small business credit applications they receive, including geographic and demographic data concerning the principal owners, lending decisions, and the price of credit. In September 2021, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a proposed rule with more than 900 pages of supplementary material. The Bureau also issued a summary of the proposed rule and a chart of the data points that the rule would require creditors to collect, and it accepted approximately 2,100 comments on the proposal in January 2022. The Bureau then issued the Final Rule on March 30, 2023, with a host of supplementary materials. In this third in a multi-post blog series (first post available here, second here), we will take a closer look at what changed between the proposed rule and the Final Rule.

On June 26, Florida Governor Ron DeSantis signed the Florida Commercial Financing Disclosure Law (FCFDL). As discussed here, the FCFDL mandates that covered commercial financing companies provide consumer-like disclosures for certain commercial financing transactions. The law also defines and prohibits specific acts by brokers of those transactions, including the collection of advance fees.

The…

After analyzing public feedback on pandemic-related forbearance programs and ways to automate and streamline long-term loss mitigation assistance, the Director of the Consumer Financial Protection Bureau (CFPB or Bureau), Rohit Chopra, issued a blogpost indicating the CFPB will be proposing ways to “simplify and streamline” mortgage servicing rules.

“Many commenters noted that borrowers seeking help…

As recently discussed on our podcast here, section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act) amended the Equal Credit Opportunity Act (ECOA) to require lenders to collect information about small business credit applications they receive, including geographic and demographic data concerning the principal owners, lending decisions, and the price of credit. The Consumer Financial Protection Bureau (CFPB or Bureau) issued its massive, highly technical, and complicated Final Rule on March 30, 2023. In this second in a multi-post blog series (the first post is available here), we will take a closer look at the data collection and reporting requirements of the Final Rule.

On June 8, the Consumer Financial Protection Bureau (CFPB), Board of Governors of the Federal Reserve System (Board), Federal Deposit Insurance Corporation (FDIC), National Credit Union Administration (NCUA), and Office of the Comptroller of the Currency (OCC) (collectively, the agencies) issued proposed guidance to financial institutions on how to incorporate reconsiderations of value (ROV) for…

With a roll-out led by Vice President Harris, the federal financial services regulators have released the long-awaited proposed automated valuation model (AVM) rule, referencing both home appraisal bias in mortgage lending and algorithmic bias, but providing no guidance at all about how to address those issues. On June 1, the Consumer Financial Protection Bureau…

Please join Troutman Pepper Partner Chris Willis and his colleagues Mark Furletti, Joe Reilly, and Christine Emello for the last installment of a special three-part series about the Consumer Financial Protection Bureau’s (CFPB) new small business lending data collection and reporting final rule — the Section 1071 rule. Part 3 focuses on specific areas, including highlighting those we worry will be especially troublesome for small business lenders.

As recently discussed on our podcast here, section 1071 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act) amended the Equal Credit Opportunity Act (ECOA) to require lenders to collect information about small business credit applications they receive, including geographic and demographic data concerning the principal owners, lending decisions, and the price of credit. The Consumer Financial Protection Bureau (CFPB or Bureau) issued its proposed rule in 2021, and after considering the over 2,500 comments it received, on March 30, 2023, the CFPB issued the massive, highly technical, and complicated Final Rule. The Final Rule and its accompanying discussion and analysis, as well as the Official Commentary totals 888 pages exclusive of the 123-page Filing Instruction Guide and numerous other documents released by the Bureau. In this first in a multi-post blog series, we will provide a high-level overview of the Final Rule.

On May 19, the Massachusetts Division of Banks entered into a consent order with Educational Computer Systems, Inc. (ECSI) to resolve allegations that ECSI was engaging in the business of a third party loan servicer or student loan servicer without the appropriate license. Under the terms of the consent order, ECSI must: 1) pay an…