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Paul Boller helps clients navigate a variety of federal and state statutory and regulatory requirements in consumer financial services.

On December 1, Freddie Mac issued Bulletin 2021-36 to update lenders on changes in loan eligibility requirements. While it is not unusual for Freddie Mac to issue such bulletins, this bulletin contained changes pertaining to cryptocurrency.

Specifically, the bulletin stated that Freddie Mac updated its Seller/Servicer Guide (the Guide) to address “the use of cryptocurrency

Last month, industry saw the Consumer Financial Protection Bureau (CFPB) issue a number of compliance aids in anticipation of two CFPB Debt Collection Final Rules becoming effective on November 30. On October 1, the CFPB issued the Debt Collection Rule FAQs, which contained questions and answers pertaining to limited-content messages and telephone call

On October 4, the Consumer Financial Protection Bureau (CFPB) announced on its website that the deadline to request initial forbearance for a COVID-19 hardship for loans backed by the Federal Housing Administration (HUD/FHA), the U.S. Department of Agriculture (USDA), or the U.S. Department of Veterans Affairs (VA) has been extended. Specifically, the CFPB tells borrowers

Earlier this summer, Minnesota extended many of its collection agency requirements to debt buyers through the enactment of H. F. No. 6. As of January 1, 2022, debt buyers will need to hold a collection agency license or have a licensing application filed with the Minnesota Department of Commerce (Department) in order to “engage[]

On June 17, the president signed legislation designating “Juneteenth National Independence Day, June 19” as a federal holiday. Because the legislation took effect immediately, it raised compliance questions for residential mortgage lenders, which must take federal holidays into account when calculating waiting periods for rescissions of closed-end loans under the Truth in Lending Act (TILA)

On June 16, the Consumer Financial Protection Bureau (CFPB) issued an interpretive rule to explain the basis for its position that the CFPB possesses the authority to “examine supervised financial institutions for risks to active duty servicemembers and their dependents (i.e. military borrowers) from conduct that violates the Military Lending Act (MLA).”

As far back

On June 28, the Consumer Financial Protection Bureau (CFPB) issued a final rule to amend Regulation Z’s mortgage servicing requirements in order to “establish temporary special safeguards to help ensure that borrowers have time before foreclosure to explore their options, including loan modifications and selling their homes.”

The rule, which applies to federally regulated mortgage

On April 27, the Bureau of Consumer Financial Protection (CFPB) issued a final rule to delay the mandatory compliance date for the General QM Final Rule until October 1, 2022. The CFPB stated that it issued the rule “to help ensure access to responsible, affordable mortgage credit and to preserve flexibility for consumers affected by

On April 5, the Consumer Financial Protection Bureau (CFPB) issued a notice of proposed rulemaking (NPR) to amend Regulation Z, specifically to “prevent avoidable foreclosures” due to the COVID-19 pandemic “as the emergency federal foreclosure protections expire.”

The NPR mainly would do three things for loans secured by a borrower’s principal residence:

  1. “[G]enerally prohibit servicers

On February 23, the Consumer Financial Protection Bureau (CFPB) issued a statement that it planned to propose a rule to “delay the July 1, 2021 mandatory compliance date of the General QM Final Rule.” Consistent with that, the CFPB announced a notice of proposed rulemaking (NPRM) on March 3, which would push back the current