The DoD s 11th Hour Interpretive Rule For New MLA Rules
|
|
- David Jacobs
- 5 years ago
- Views:
Transcription
1 The DoD s 11th Hour Interpretive Rule For New MLA Rules September 20, 2016 Moderator Alan S. Kaplinsky Practice Leader Consumer Financial Services kaplinsky@ballardspahr.com Panelists John L. Culhane, Jr. Partner Consumer Financial Services culhane@ballardspahr.com Anthony C. Kaye Partner Consumer Financial Services kaye@ballardspahr.com Juliana D. Gerrick Associate Consumer Financial Services gerrickj@ballardspahr.com Copyright 2016 Ballard Spahr LLP. All rights reserved.
2 Resources CFPB Monitor Subscribe to our ABA award-winning blog at E-Alerts Subscribe at (click subscribe and indicate your areas of interest) Mortgage Banking Update Subscribe at (click subscribe and choose Mortgage Banking as your area of interest) Questions? 2
3 Upcoming Webinars HOA Super-Lien Litigation: The Latest Events, Trends, and What May Come Next New European Data Privacy Rules What Global Financial Institutions Need to Know The CFPB's Final Prepaid Account Rule September 21 September 27 October 20 Register for upcoming webinars at or by ing Request materials from past webinars by ing 3
4 Your Presenters Alan S. Kaplinsky John L. Culhane, Jr. Anthony C. Kaye Juliana D. Gerrick 4
5 Def. of Consumer Credit (Questions 1-2) Overdraft products - Follows treatment of overdraft coverage under Regulation Z - Overdrafts not made pursuant to a written agreement are outside of the MLA Purchase money financing exclusion for personal property - Somewhat ambiguous answer as to application of exclusion Hybrid purchase money and cash advance loan not excluded Financing unrelated to the purchase not excluded Additional cash-out financing not excluded Loan must finance only the acquisition to be excluded - Similar exclusions for personal property and motor vehicles What about negative equity and financing of add-on products? 5
6 MAPR General (Questions 3-5) MAPR in excess of 36% in a billing cycle for open-end credit - To comply, fees or finance charges may be waived in whole or in part Fees imposed on creditor by law and passed through to borrower - Are not finance charges under Regulation Z and therefore may be excluded from the calculation of MAPR No balance billing cycle for open-end credit - Fees or charges not included in the calculation of MAPR may be assessed in periods where the balance is zero 6
7 MAPR Credit Cards (Questions 6-8) Minimum interest charge - May be a bona fide fee excludable from the MAPR Sources of information for bona fide fee calculations - Not restricted to SEC filings or Call Reports - May rely on commercially available databases or other industry sources Participation fee - Impact of rewards program may be considered in determining overall reasonableness - Rewards program benefits may also be considered in determining whether fee amount is less than or equal to average amount for substantially similar product or service 7
8 Safe Harbor (Questions 9-11) Assignees may have the benefit of the safe harbor - Assignee must maintain the safe harbor records of the creditor Periodic screening of credit portfolios for risk management or other purposes is permitted - However, safe harbor may not be established by lookback MLA database internet address is not fixed - Don t confuse the MLA database with the SCRA database 8
9 Disclosure Issues (Questions 12-14) Options for oral disclosure of payment obligation - Provide exact information from payment schedule - Provide information based on estimate of amount borrowed - Provide generic description of payment schedule Availability of information provided through toll-free phone number - Only has to be available for a duration of time reasonably necessary to allow a covered borrower to contact the creditor Providing MLA disclosures after borrower becomes obligated - MLA timing requirements do not override provisions in Regulation Z - MLA disclosures need not be separately provided in such situations (purchase orders or requests for credit made by mail, telephone, or fax) 9
10 Savings Clause (Question 15) Single agreement for both covered and non-covered borrowers - Permissible so long as any prohibited terms are limited in application to only noncovered borrowers by use of a savings clause 10
11 Bank Account Access (Questions 16-18) Covered borrower is not prohibited from repaying by check or EFT - Recurring payments complying with Regulation E are permissible - But no security interests in remotely created checks or money orders - And no post-dated checks Covered borrower may grant a security interest in his or her account - Security interest is not limited to funds deposited after credit is extended (?) - But creditor may not charge MAPR in excess of 36% Creditor may exercise a statutory interest in deposited funds - Statutory lien applies regardless of time of deposit - But creditor may not charge MAPR in excess of 36% 11
12 Vehicle Security Interest (Question 19) Definition of vehicle - Does not include motor homes, RVs, golf carts, or motor scooters 12
13 State Antidiscrimination Laws The following states prohibit discrimination against servicemembers specifically in the context of credit decisions or in general: - Arkansas (credit) - California (credit) - Indiana (credit) - Michigan - Missouri - Minnesota - New York (credit) - North Carolina - Ohio (credit) - Rhode Island (credit) - Washington (credit) 13
14 Thank you for joining us! Moderator Alan S. Kaplinsky Practice Leader Consumer Financial Services Panelists John L. Culhane, Jr. Partner Consumer Financial Services Anthony C. Kaye Partner Consumer Financial Services Juliana D. Gerrick Associate Consumer Financial Services
15 Moderator Alan S. Kaplinsky Practice Leader of the Consumer Financial Services Group at Ballard Spahr Devotes his practice to counseling financial institutions with respect to bank regulatory and transactional matters and defending them in individual and class action lawsuits (including CFPB investigations and government enforcement matters) First President of the American College of Consumer Financial Services Lawyers and the recipient of the College s 2016 Lifetime Achievement Award Former Chair of the American Bar Association Committee on Consumer Financial Services of the Business Law Section Co-Chair of the Practising Law Institute's Annual Consumer Financial Services Institute, now on its 21 st year Has been named as a tier one banking and consumer financial services lawyer in the 2006 through 2016 editions of Chambers USA Has been named in The Best Lawyers in America under financial services regulation law and banking and finance litigation from 2007 to 2015 Member of the Bloomberg BNA Banking Report Advisory Board Recipient of the National Law Journal's 2015 Litigation Trailblazers Award for pioneering the use of class action waivers in consumer arbitration provisions 15
16 Panelist John L. Culhane, Jr. Partner at Ballard Spahr and a member of the firm s Consumer Financial Services, Mortgage Banking, Bank Regulation and Supervision, Higher Education, and Privacy and Data Security Groups as well as its Marketplace Lending Task Force, Fair Lending Task Force, TCPA Task Force, and Military Lending Act Task Force Compliance practice emphasizes counseling clients on the development and implementation of innovative loan, leasing, and payment programs, and includes counseling on fair lending, servicing and collection issues Regulatory practice includes preparing clients for banking agency and CFPB targeted fair lending and full spectrum compliance examinations as well as assisting in the defense of consumer class actions, attorney general investigations, and agency enforcement actions Named a top consumer financial services lawyer by Chambers USA, 2015 & 2016 Charter member of the American College of Consumer Financial Services Lawyers Former Chair of the Subcommittee on Fair Lending of the ABA Committee on Consumer Financial Services 16
17 Panelist Anthony C. Kaye Partner at Ballard Spahr and a member of the firm s Consumer Financial Services and Mortgage Banking Groups Focuses on business litigation and complex civil litigation at both the trial and appellate levels in federal and state courts throughout the United States Counsels financial institutions on regulatory matters, advises them on compliance with consumer financial services laws (including the SCRA and MLA), and defends them in both individual and class action lawsuits Member of the ABA Committee on Consumer Financial Services 17
18 Panelist Juliana D. Gerrick Associate at Ballard Spahr and a member of the firm s Consumer Financial Services Group Advises institutions on federal and state consumer finance laws, including those governing fair lending, credit reporting, privacy, marketing, payments, debt collection, military lending, and unfair, deceptive, and abusive acts and practices Counsels providers of consumer financial services, including banks, on regulatory compliance matters and preparing for examinations by the Consumer Financial Protection Bureau (CFPB) Prior to joining the firm, Ms. Gerrick was a Management Associate for Citigroup, Inc., where she worked in Citi Cards Compliance, Retail Banking Compliance, AML Advisory Compliance, and Fixed Income Compliance Ms. Gerrick has also clerked for the State of California s Office of the Attorney General, Corporate Fraud and Securities Unit 18
How to Ace Your CFPB Exam
How to Ace Your CFPB Exam May 25, 2016 Moderator Alan S. Kaplinsky Practice Leader Consumer Financial Services 215.864.8544 kaplinsky@ballardspahr.com Panelists Richard J. Andreano, Jr. Practice Leader
More informationPushing the Envelope: Are There Any Limits to the CFPB s Jurisdiction?
Pushing the Envelope: Are There Any Limits to the CFPB s Jurisdiction? August 18, 2015 Moderator Alan S. Kaplinsky Practice Leader Consumer Financial Services 215.864.8544 kaplinsky@ballardspahr.com Panelists
More informationThrough the Crystal Ball: Predicting Important CFPB Developments in 2015
Through the Crystal Ball: Predicting Important CFPB Developments in 2015 April 2, 2015 Moderator Alan S. Kaplinsky Practice Leader Consumer Financial Services 215.864.8544 kaplinsky@ballardspahr.com Panelists
More informationFinCEN's Customer Due Diligence Final Rule What You Need To Know
FinCEN's Customer Due Diligence Final Rule What You Need To Know June 2, 2016 Moderator Alan S. Kaplinsky Practice Leader Consumer Financial Services 215.864.8544 kaplinsky@ballardspahr.com Panelists Peter
More informationNavigating Compliance Audit Pitfalls:
Navigating Compliance Audit Pitfalls: How To Prepare Compliance and Audit Reports Without Providing a Road Map to Adversaries June 4, 2015 Moderator Alan S. Kaplinsky Practice Leader Consumer Financial
More informationLeveling the Playing Field CFPB Regulations and Guidance Targeted for Review by Treasury Under President Trump s February 3 Executive Order
Leveling the Playing Field CFPB Regulations and Guidance Targeted for Review by Treasury Under President Trump s February 3 Executive Order March 6, 2017 Moderator Richard J. Andreano, Jr. Practice Leader
More informationABA Updated Staff Analysis: Interpretive Rule of the Military Lending Act Regulation
ABA Updated Staff Analysis: Interpretive Rule of the Military Lending Act Regulation August 30, 2016 The Department of Defense (DoD) s interpretive rule to its Military Lending Act Rule (MLA Rule) was
More informationInsurance Coverage for Governmental Investigations
Insurance Coverage for Governmental Investigations Ballard Spahr LLP Alan S. Kaplinsky, Practice Leader Consumer Financial Services kaplinsky@ballardspahr.com 215.864.8544 Christopher J. Willis, Partner
More informationChanges to the Military Lending Act: Is Your Credit Union Ready? Today s Presenters. Disclaimer 9/13/2016
Changes to the Military Lending Act: Is Your Credit Union Ready? Copyright 2016 by Credit Union National Association. All rights reserved. These materials may not be reproduced in whole or in part, in
More informationCFPB Update. COHEAO Annual Conference. January 29, 2018 Arlington, VA. Heather S. Klein, Associate
CFPB Update COHEAO Annual Conference January 29, 2018 Arlington, VA John L. Culhane, Jr., Partner Consumer Financial Services Group Higher Education Group 215.864.8535 culhane@ballardspahr.com Heather
More informationMilitary Lending Act: How LOANLINER Document Solutions Can Help
Presented by: Military Lending Act: How LOANLINER Document Solutions Can Help Casey Hunt Portfolio & Compliance Manager CUNA Mutual Group Proprietary Reproduction, Adaptation or Distribution Prohibited
More informationCFPB Laws and Regulations
Military Lending Act () Interagency Examination Procedures 2015 Amendments Background The Military Lending Act 1 (), enacted in 2006 and implemented by the Department of Defense (DoD), protects active
More informationDepartment of Defense Final Rule
Department of Defense Final Rule Limitations on Terms of Consumer Credit Extended to Service Members and Dependents September 8, 2015 Department of Defense Final Rule Limitations on Terms of Consumer Credit
More informationMilitary Lending Act: Exam Procedure Changes, Post-Implementation Considerations & FAQs
Military Lending Act: Exam Procedure Changes, Post-Implementation Considerations & FAQs M. Elizabeth Fast, Esq. Spencer Fane LLP Phone: (800) 526-6529 toll free Fax: (816) 474-3216 efast@spencerfane.com
More informationWelcome to the Military Lending Act Roundtable
Welcome to the Military Lending Act Roundtable Are you in the new Councils Community? Join your Lending Council peers and members of all six Councils in 13 Discussion Communities today! Visit the Community
More informationMilitary Lending Act Amendments Effective: 10/03/ Loans and Open-end lines
Military Lending Act Amendments Effective: 10/03/2016 - Loans and Open-end lines Presented by: Pam Perdue EVP Regulatory Insight, Continuity 10/03/2017 - Credit cards Presented September 2016 Presenting
More informationAuto Finance Industry in the CFPB's Crosshairs
Auto Finance Industry in the CFPB's Crosshairs April 16, 2013 Alan S. Kaplinsky, Practice Leader Consumer Financial Services 215.864.8544 kaplinsky@ballardspahr.com John L. Culhane, Jr. Consumer Financial
More informationAn Eye on the Bureau An Update from CFPB Monitor
An Eye on the Bureau An Update from CFPB Monitor The CFPB Is Coming! The CFPB Is Coming! COHEAO Annual Conference January 28, 2013 NCHER Knowledge Symposium November 7, 2012 John L. Culhane, Jr., Partner
More informationSHAPING THE FUTURE. CFPB HOLDING ITS FIRE
1 of 5 10/23/2014 9:53 AM October 3, 2014 - In This Issue: News from AFSA SHAPING THE FUTURE. AFSA SPEAKS OUT AGAINST PENTAGON PROPOSAL CFPB HOLDING ITS FIRE CFPB TARGETS PRICE DISPARITY APPEALS COURT
More informationMortgage Banking. Solutions in Compliance, Transactions, and Defense. Attorney Advertising
Mortgage Banking Solutions in Compliance, Transactions, and Defense Attorney Advertising The mortgage banking industry is changing rapidly. We offer broad regulatory experience, formidable skill in litigation,
More informationChanges to the Military Lending Act. Disclaimer. Agenda 9/10/2015
Changes to the Military Lending Act Presented by Michael R. Christians Compliance Attorney PolicyWorks, L.L.C. The services of PolicyWorks and this presentation, including all materials, should not be
More informationHow Credit Unions Will Be Impacted by the DoD Proposed Rule
How Credit Unions Will Be Impacted by the DoD Proposed Rule Presented by: Quincy Enoch, Associate Director, Legislative Affairs & Military Liaison National Association of Federal Credit Unions qenoch@nafcu.org
More informationWith so much change, be sure to stay up to date!
With so much change, be sure to stay up to date! Glory LeDu Glory.LeDu@mcul.org Sarah Stevenson Sarah.Stevenson@mcul.org Barb Boyd Barb.Boyd@cusolutionsgroup.com Your Crazy Compliance Peeps Agenda What
More informationThe CFPB s First Anniversary: A Look Back at What is has Accomplished and Where it is Headed December 13, 2012
The CFPB s First Anniversary: A Look Back at What is has Accomplished and Where it is Headed December 13, 2012 Alan S. Kaplinsky, Practice Leader Consumer Financial Services Group Ballard Spahr LLP 1735
More informationRegulatory Update from Washington DC October 5, 2016
2017 Northwest Compliance Conference Seattle, Washington Regulatory Update from Washington DC October 5, 2016 Nessa Feddis American Bankers Association ABA National Update Bureau generally Regulatory relief
More informationLending to Military Members: The Servicemembers Civil Relief Act and Military Lending Act Final Rule
Lending to Military Members: The Servicemembers Civil Relief Act and Military Lending Act Final Rule Louisiana Bankers Association 2015 Bank Counsel Conference December 11, 2015 Presented by: Laura Brown,
More informationTHE MILITARY LENDING ACT
SMITH DEBNAM NARRON DRAKE SAINTSING & MYERS, LLP THE MILITARY LENDING ACT By Franklin Drake (919) 250-2109 fdrake@smithdebnamlaw.com The Military Lending Act ( MLA ) was initially created to protect military
More informationShort-Term, Small-Dollar Lending
Commonly Known as Payday Lending Exam Date: Prepared By: Reviewer: Docket #: Entity Name: [Click&type] [Click&type] [Click&type] [Click&type] [Click&type] These examination procedures apply to the short-term,
More information7/9/18. PF SMS icons. Military Consumer Protection Awareness. MFLN Intro. PF SMS icons. Military Consumer Protection Awareness.
PF SMS icons PF SMS icons Military Consumer Protection Awareness Thanks for joining us! We will get started soon. While you re waiting you can get handouts etc. by following the link below: http://militaryfamilieslearningnetwork.org/event/21098
More informationRegulatory Compliance Update. Hoi Luk, Senior Manager, Financial Services Consulting
Regulatory Compliance Update Hoi Luk, Senior Manager, Financial Services Consulting What are WE Seeing and Hearing? Supervisory Committee Workshop 3 Supervisory Letter SL 17-01 March 29, 2017 Evaluating
More informationLoan Growth and Compliance Pitfalls
Loan Growth and Compliance Pitfalls presented by LOANLINER Compliance Information provided in this presentation, including all materials, should not be construed as legal services, legal advice, or in
More informationNotice on Defense Department s New Rules for Consumer Loans to Service Members
Notice on Defense Department s New Rules for Consumer Loans to Service Members The Department of Defense has finalized a regulation for consumer payday loans, vehicle title loans, and tax refund anticipation
More information2/4/2014. Consumer Financial Protection Bureau Update A New Era of Regulation Begins. A Quick Overview of the CFPB. CFPB Overview (cont.
Consumer Financial Protection Bureau Update A New Era of Regulation Begins A Quick Overview of the CFPB The CFPB was created by Title X of the Dodd-Frank Act and became operational on July 21, 2011 Independent
More informationFair Lending TILA and RESPA Integrated Disclosures ( TRID ) and Consumer Financial Protection Bureau ( CFPB )
Fair Lending TILA and RESPA Integrated Disclosures ( TRID ) and Consumer Financial Protection Bureau ( CFPB ) Presented by Anthony J. Sylvester, Esq. Craig L. Steinfeld, Esq. Sherman Wells Sylvester &
More informationMilitary Lending Act Limitations on Terms of Consumer Credit Extended to
This document is scheduled to be published in the Federal Register on 12/14/2017 and available online at https://federalregister.gov/d/2017-26974, and on FDsys.gov BILLING CODE: 5001-06 DEPARTMENT OF DEFENSE
More informationU.S. Consumer Financial Services Regulation: What to Expect in 2016
U.S. Consumer Financial Services Regulation: What to Expect in 2016 Digital Payments Intensive April 13, 2016 Andrew J. Lorentz No. 1 RULEMAKING BY ENFORCEMENT 2 Rulemaking by enforcement New Consumer
More informationDebtors and Creditors
October 2018 Volume 106 Number 10 Page 44 The Magazine of Illinois Lawyers Debtors and Creditors The Sharpened Teeth of the Military Lending Act By Michael D. Schag The Military Lending Act's fairly stringent
More informationCONSUMER FINANCIAL SERVICES: SUPERVISION, ENFORCEMENT & LITIGATION
CONSUMER FINANCIAL SERVICES: SUPERVISION, ENFORCEMENT & LITIGATION Davis Wright Tremaine LLP (DWT) is a firm of approximately 550 lawyers in nine offices in the U.S. and China. DWT s consumer financial
More informationLeslie L. Abbott. Los Angeles. Practice Areas. Admissions. Education. Partner, Employment Law Department
Leslie L. Abbott Partner, Employment Law Department leslieabbott@paulhastings.com Leslie Abbott is a partner and co-chair of the Los Angeles Employment Law Department of Paul Hastings, where she has practiced
More informationThe Salcido Report. False Claims Act Public Disclosure Alert. If you read one thing...
The Salcido Report September 25, 2015 If you read one thing... Launch of a new False Claims Act (FCA) resource The Public Disclosure Alert (PDA) provides expert analysis of latest paradigm shifting FCA
More informationDavid K. Stein. Partner. Professional & Community Activities
David Stein is chair of Bricker & Eckler's Banking & Financial Services group and maintains a national practice in this area of law. He advises businesses on consumer-facing issues, including real estate,
More informationThe CFPB s Priorities in Rulemaking, Supervision, and Enforcement
The CFPB s Priorities in Rulemaking, Supervision, and Enforcement July 21, 2016 Scott M. Pearson Ballard Spahr LLP 424.204.4323 pearsons@ballardspahr.com John D. Socknat Ballard Spahr LLP 202.661.2253
More informationGregory Keating. Practice Group Leader PRACTICE FOCUS. EDUCATION Boston College Law School JD, 1993, cum laude. Trinity College BA, 1987
Gregory Keating Practice Group Leader T +1 (617) 248-5065 gkeating@choate.com a respected expert in the defense of whistle-blower claims and for his phenomenal expertise representing clients in the education
More informationHow to Use This Service
BANKER S GUIDE TO COMPLIANCE How to Use This Service The Banker s Guide to Compliance is written in bankers language and intended for use by bankers. You need not be a lawyer or compliance expert to use
More informationMATTHEW J. RENAUD, Partner. MATTHEW J. RENAUD Partner
MATTHEW J. RENAUD, Partner Matthew J. Renaud is a partner in Jenner & Block s Chicago office. He is chair of the firm s Employee Benefits and Executive Compensation Practice, a member of the Private Equity/Investment
More informationMilitary Lending Act. Presented by Kris McIsaac
Presented by Kris McIsaac 04.28.2017 Why is compliance with the MLA so important?? **Credit Agreements in violation of the MLA are VOID FROM INCEPTION!! Who is covered? Covered Borrower A consumer who,
More informationThe Compliance Challenges of Credit Union Collections. Collections and Compliance?
The Compliance Challenges of Credit Union Collections Presented by Maria Peyton NSWC Federal Credit Union Collections and Compliance? Yes! It is about more than just collecting a debt Collectors must be
More informationABA Compliance School Foundational
ABA Compliance School Foundational Deposit/Operations Module March 10 13, 2018 Grand Hyatt Denver Denver, Colorado COURSE CATALOG aba.com 1-800-BANKERS October 2014 Session Emory Conference Center and
More informationEMERGING CONSUMER RISKS FOR COMMUNITY BANKS
November 14, 2016 1 EMERGING CONSUMER RISKS FOR COMMUNITY BANKS 2016 ANNUAL RISK MANAGEMENT CONFERENCE NOVEMBER 14, 2016 November 14, 2016 2 Paul J. Stark, SVP & Chief Credit Officer Civista Bank, Sandusky
More informationDodd-Frank Chapter X: The Consumer Financial Protection Bureau
Association of Corporate Counsel (ACC) Financial Services Committee Legal Quick Hit Lewis S. Wiener March 23, 2011 Dodd-Frank Chapter X: The Consumer Financial Protection Bureau The Consumer Financial
More informationPayday Lending Provision 2007 Defense Authorization Bill
Payday Lending Provision 2007 Defense Authorization Bill Overview H.R. 5122, the John Warner National Defense Authorization Act for Fiscal Year 2007, includes a provision (Subtitle F, Section 670) originally
More informationIAM SURE MOST OF YOU HAVE BEEN ON A ROLLER COASTER at
The Compliance Regulatory Roller Coaster Just A LOOK AHEA IAM SURE MOST OF YOU HAVE BEEN ON A ROLLER COASTER at some point in your lives. The ride provides thrills, drops, hills, sharp turns, high speeds,
More informationPART 232 LIMITATIONS ON TERMS OF CONSUMER CREDIT EX- TENDED TO SERVICE MEMBERS AND DEPENDENTS
Office of the Secretary of Defense 232.1 neither a banking office nor an on-base credit union, use the solicitation process outlined in 231.5(c) of this chapter, as supplemented by the provisions outlined
More informationPowerPoint Presentation INCLUDING COMPLIANCE IN THE BANK S RISK PROGRAM
PowerPoint Presentation INCLUDING COMPLIANCE IN THE BANK S RISK PROGRAM Chuck Lewis Vice President, Compliance Services Missouri Bankers Association Jefferson City, Missouri clewis@mobankers.com 573-301-1884
More informationWhat You Need to Know About the CFPB s Short-Term, Small- Dollar Lending Examination Procedures
What You Need to Know About the CFPB s Short-Term, Small- Dollar Lending Examination Procedures Richard P. Eckman Timothy R. McTaggart Pepper Hamilton LLP John C. Soffronoff, Jr. ICS Risk Advisors September
More informationKevin Patterson Partner
100 Quentin Roosevelt Boulevard Garden City, NY 11530-4850 ph: 516.296.9196 fx: 516.357.3792 kpatterson@cullenanddykman.com AREAS OF PRACTICE Banking Compliance Bank Operations Bank Regulatory and Compliance
More informationAny person, who for direct or indirect compensation, assists a consumer in obtaining or applying to obtain a residential mortgage loan; or
Mortgage Reform and Anti-Predatory Lending Act Although it has received far less attention than other titles of the Dodd-Frank Act (the Act or Dodd-Frank ), such as those addressing derivatives, too big
More information81 LAWYER S PARTICIPATION IN PREPAID
Formal Opinions Opinion 81 81 LAWYER S PARTICIPATION IN PREPAID LEGAL SERVICE PLANS Adopted March 18, 1989. Introduction and Scope Over the past few years, the Committee has received a number of inquiries
More informationWm. Cary Wright. education. related practices. related industries. bar admissions. court admissions.
Wm. Cary Wright Shareholder cwright@carltonfields.com Tampa T: 813.229.4135 F: 813.229.4133 education Stetson University College of Law (J.D., 1990), cum laude University of Florida (B.S. in Accounting,
More informationAdam P. Jaskievic Associate Attorney American Mortgage Law Group, P.C.
Adam P. Jaskievic Associate Attorney American Mortgage Law Group, P.C. Mr. Jaskievic is an associate attorney with the American Mortgage Law Group, P.C. s Boston, Massachusetts office. He routinely advises
More informationSheshunoff Consulting + Solutions (SCS)
This Military Lending Act resource is an unofficial transcript of the NCUA s Preparing to Comply with Regulatory Changes under the Military Lending Act webinar that was held on June 29, 2016. This document
More informationJune 21, The Honorable James Mattis Secretary of Defense 1000 Defense Pentagon Washington, DC Dear Mr.
June 21, 2017 The Honorable James Mattis Secretary of Defense 1000 Defense Pentagon Washington, DC 20301-1000 Dear Mr. Secretary, As we approach the first anniversary of the implementation of the Department
More informationWHAT YOUR ORGANIZATION NEEDS TO KNOW ABOUT INSURANCE & RISK MANAGEMENT:
WHAT YOUR ORGANIZATION NEEDS TO KNOW ABOUT INSURANCE & RISK MANAGEMENT: A SERIES OF WEBINARS DESIGNED TO HELP YOU PROTECT YOUR NONPROFIT Sponsored by: Join us for a four-part series on the steps your organization
More informationLawrence J. Bracken II Partner
Biographies Lawrence J. Bracken II Partner lbracken@huntonak.com Atlanta +1 404 888 4035 New York +1 212 309 1054 SERVICES Industries Energy Financial Services Retail and Consumer Products Practices Insurance
More informationNew update of Bloomberg Law MARC records. February 21, Dear Valued Subscribers,
New update of Bloomberg Law MARC records February 21, 2019 Dear Valued Subscribers, We have just posted an update of MARC records for Bloomberg Law. The records are available free of charge on the Bloomberg
More informationSummary of Credit Terms. This APR will vary with the market based on the Prime Rate. This APR will vary with the market based on the Prime Rate.
Interest Rates and Interest Charges Annual Percentage Rate (APR) for Purchases 14.99%. APR for Balance Transfers 14.99%. APR for Cash Advances 26.25%. Summary of Credit Terms Penalty APR and When it Applies
More informationTITLE VII WALL STREET REFORM AND CONSUMER PROTECTION ACT OF 2009 (FORMERLY H.R. 1728)
TITLE VII WALL STREET REFORM AND CONSUMER PROTECTION ACT OF 2009 (FORMERLY H.R. 1728) Section 102 Section 103 Section 104 Section 106 Section 107 Section 201 Section 202 Section 203 Title I: Residential
More informationServicemember Financial Protection
Servicemember Financial Protection Outlook Live Webinar September 10, 2012 An Interagency Discussion of Recent Servicemember Financial Protection Guidance and Compliance with the Servicemembers Civil Relief
More informationRe: Request for Information Regarding Bureau Enforcement Processes (Docket No. CFPB )
May 14, 2018 By Electronic Submission Ms. Monica Jackson Office of the Executive Secretary Consumer Financial Protection Bureau 1700 G Street NW Washington, DC 20552 www.regulations.gov Jan Stieger, CMP,
More informationUDAAP: The CFPB s Emerging and Evolving Doctrine
UDAAP: The CFPB s Emerging and Evolving Doctrine October 5, 2016 Moderator: Allyson Baker, Esq., Partner, Venable LLP Panelists: Jennifer McCabe, Vice President, Cornerstone Research Meredith Boylan, Esq.,
More informationSummary of Debt Collection Proposals Under Consideration 1
I. Executive Summary Summary of Debt Collection Proposals Under Consideration 1 On July 28, 2016, the Consumer Financial Protection Bureau ( CFPB or Bureau ) released its 117 page outline for debt collection
More informationSummary of Final CARD Act Clarifications
April 8, 2011 Summary of Final CARD Act Clarifications By L. Richard Fischer, Oliver I. Ireland and Obrea O. Poindexter On March 18, 2011, the Federal Reserve Board ( FRB ) issued a final rule to clarify
More informationBest Practices for Borrower Ability to Repay Rules
March 30, 2012 Best Practices for Borrower Ability to Repay Rules by Anna DeSimone President & Founder About one year ago, I published an article entitled Borrower Repayment Ability on the Radar. The article
More informationMORTGAGE LENDER LICENSE APPLICATION PACKET
(503) 378-4140 Fax: (503) 947-7862 TTY: (503) 378-4100 MORTGAGE LENDER LICENSE APPLICATION PACKET Please read instructions before completing application. CONTENTS: Application instructions Application
More information18.24% when you open your account.
The following notice applies if you received a pre-selected offer for a credit card from us. You can choose to stop receiving prescreened offers of credit from this and other companies by calling toll-free
More informationTIS Advertising Compliance Presented by John Zasada. John Zasada. CliftonLarsonAllen LLP
TIS Advertising Compliance Presented by John Zasada John Zasada CliftonLarsonAllen LLP 218 790 1086 Agenda Advertising compliance importance Managing advertising compliance UDAAP Terminology APY disclosure
More informationTemenos USA, Inc All rights reserved.
Temenos USA, Inc. 2017. All rights reserved. TRID: THE REALLY IMPORTANT DETAILS Temenos USA, Inc. 2017. All rights reserved. WHAT YOU WILL LEARN 3 1. Brief Overview a) Coverage b) Key Definitions c) Timing
More informationColorado Revised Statutes Title 12 Professions and Occupations General Article 14.3 Colorado Consumer Credit Reporting Act
Colorado Revised Statutes Title 12 Professions and Occupations General Article 14.3 Colorado Consumer Credit Reporting Act 12-14.3-106.6. Security freeze - timing - covered entities - cost (1) (a) A consumer
More informationClaudia Callaway Christina J. Grigorian
November 17, 2016 Claudia Callaway Christina J. Grigorian Katten Muchin Rosenman LLP Claudia Callaway Partner +1.202.625.3590 claudia.callaway@kattenlaw.com Claudia Callaway is chair of Katten's Consumer
More informationNational Independent Automobile Dealers Association
To: From: Re: National Independent Automobile Dealers Association Shaun K. Petersen February 2015 Regulatory Update Date: March 2, 2015 I. Consumer Financial Protection Bureau A. Complaint Portal On-Boarding
More informationProbate and Administration of Decedents Estates
New York Lawyers Practical Skills Series Includes Forms on CD Probate and Administration of Decedents Estates Jessica R. Amelar, Esq. Arlene Harris, Esq. 2016 2017 NEW YORK STATE BAR ASSOCIATION Sponsored
More informationCFPB Releases FDCPA Rule Outline; Creditor Collection Rule to Come
Consumer Financial Services Update CFPB Releases FDCPA Rule Outline; Creditor Collection Rule to Come July 29, 2016 On July 28, 2016, the Consumer Financial Protection Bureau (CFPB) released an outline
More informationHealth Care Practice Center
Health Care Practice Center Power your practice. 800.372.1033 bna.com/bloomberglaw Seamlessly integrated intelligence. Practice pages Navigate the nuances of health care law. Bloomberg Law s Health Care
More informationElectronic Media Liability A New Look to an Old Problem. Sponsored By:
Electronic Media Liability A New Look to an Old Problem Sponsored By: 1 About Advisen Advisen generates, integrates, analyses and communicates unbiased, real-time insights for the global community of commercial
More informationThe Commercial Real Estate Lending Decision Process Series (RMA)
Business Banking & Commercial Lending Analyzing Business Financial Statements and Tax Returns Analyzing Financial Statements Analyzing Personal Financial Statements and Tax Returns Certificate in Business
More informationCARTERS CHARITY FIRM PROFILE
CARTERS CHARITY FIRM PROFILE A FULL SERVICE LAW FIRM WITH A FOCUS ON CHARITIES AND NOT-FOR-PROFIT ORGANIZATIONS Carters Professional Corporation (Carters) is one of the leading firms in Canada in the area
More informationNC Student Assist Education Loan Terms and Conditions
NC Student Assist Education Loan Terms and Conditions SECTION 1 DEFINITIONS These definitions explain what particular words mean in these Terms and Conditions. Capitalized Interest means any accrued, unpaid
More informationNCCO Exam Study Guide
NCCO Exam Study Guide The questions on the NCCO exams are drawn from material contained in NAFCU s Credit Union Compliance GPS. Purchase of the Compliance GPS is not required in order to take the NCCO
More informationExpert Analysis Understanding the Evolving Legal And Regulatory Landscape for Consumer Marketplace Lending
Westlaw Journal bank & Lender Liability Litigation News and Analysis Legislation Regulation Expert Commentary VOLUME 21, issue 19 / february 8, 2016 Expert Analysis Understanding the Evolving Legal And
More informationQuestions About This Publication
Questions About This Publication For assistance with shipments, billing or other customer service matters, please call our Customer Service Department at: 1-631-350-2100 To obtain a copy of this book,
More informationProduct and Special Pricing Information 05/12
Product and Special Pricing Information 05/12 Package Information Comprehensive pre-employment screening technology meets unequaled customer service in a variety of convenient packages. Our most frequently
More informationRegulatory Compliance Update
Regulatory Compliance Update ACUIA Region 6 Conference Presented By: Kristie Kenney Hoover, NCCO Internal Audit Manager, Doeren Mayhew Florida Michigan North Carolina Texas Insight. Oversight. Foresight.
More informationEdward J. Corey, Jr. Shareholder
ecorey@weintraub.com t: 916.558.6017 f: 916.446.1611 PRACTICE AREAS Trusts and Estates Trust and Estate Litigation Elder Abuse and Fiduciary Abuse Litigation Conservatorships Trust and Probate Administration
More informationHelping Older Americans Cope with Medical Debt
Helping Older Americans Cope with Medical Debt Cheryl Fish-Parcham, Families USA Chi Chi Wu, National Consumer Law Center Odette Williamson & Jessica Hiemenz National Consumer Law Center National Elder
More informationCHANGING THE WORLD OF REAL ESTATE. Presented By: THOMAS RICHARDSON
CHANGING THE WORLD OF REAL ESTATE Presented By: THOMAS RICHARDSON 1. What is the CFPB? 2. A World of Acronyms 3. The Qualified Mortgage 4. RESPA 5. Closing Disclosures vs. HUD 6. Lender Liability 7. Best
More informationTable of Contents CLICK ANY TITLE TO GO DIRECTLY TO THAT SECTION. SUBTITLE A: Bureau of Consumer Financial Protection
Venable CFPB monitor Please contact our attorneys in our CFPB Task Force if you have any questions regarding this information. Table of Contents CLICK ANY TITLE TO GO DIRECTLY TO THAT SECTION Last updated
More informationDouglas Edward Smith. Focus Areas. Overview. Professional and Community Affiliations
Shareholder One Union Square 600 University Street, Suite 3200 98101 main: (206) 623-3300 direct: (206) 381-4906 fax: (206) 447-6965 desmith@littler.com Focus Areas Class Actions Litigation and Trials
More informationConsumer Federation of America Best Practices for Identity Theft Services. March 10, 2011
Consumer Federation of America Best Practices for Identity Theft Services March 10, 2011 Consumer Federation of America Best Practices for Identity Theft Services Table of Contents Introduction 3 About
More informationdirect Assistant: Debbie Harris
RICHARD A. JOHNSON Partner 615.850.8151 direct richard.johnson@wallerlaw.com Assistant: Debbie Harris 615.850.8148 debbie.harris@wallerlaw.com Nashville City Center 511 Union Street Suite 2700 Nashville,
More informationCarrington Mortgage Services, LLC
Dear Mortgagor(s), Carrington Mortgage Services, LLC ( we, us or CMS ) offers you the option to automatically make your mortgage payments each month by having us debit an account you designate on the eligible
More information