CFPB Issues Procedural Rule Establishing a Pilot Advisory Opinion Program

In Client and Friends Memos by BMG Memorandum

In the June 22, 2020 issue of the Federal Register (85 FR 37331, click here), the Bureau of Consumer Financial Protection (Bureau) announced the establishment of a pilot advisory opinion program (Pilot AO Program). Under the Pilot AO Program, requestors will be able to request interpretive guidance, in the form of an advisory opinion (AO), to resolve regulatory uncertainty, which …

CFPB Issues Proposed Procedural Rule for Advisory Opinion Program

In Client and Friends Memos by BMG Memorandum

In the June 22, 2020 issue of the Federal Register (85 FR 37394, click here), the Bureau of Consumer Financial Protection (Bureau) requests the public to comment on a new advisory opinion program (Proposed AO Program), and a proposed information collection associated with requests submitted by persons requesting advisory opinions under the Proposed AO Program. This Proposed AO Program is …

FHA Expands Home Retention Measures for Homeowners Financially Impacted by COVID-19 in Mortgagee Letter 2020-22

In Client and Friends Memos, FHA by BMG Memorandum

On July 8, 2020, the Federal Housing Administration (FHA) issued Mortgagee Letter 2020-22 (ML 2020-22, click here) that informs mortgagees of additional home retention measures to help homeowners with FHA-insured single family mortgages who are financially impacted by the COVID-19 pandemic to bring their mortgage current at the end of their COVID-19 forbearance. Full Memorandum

Flood Insurance Proposed Interagency Questions and Answers

In Client and Friends Memos by BMG Memorandum

In the July 6, 2020, issue of the Federal Register (85 FR 40442, click here), the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), the Farm Credit Administration (FCA), and the National Credit Union Administration (NCUA), (collectively the “Agencies”), jointly published proposed Interagency Questions and Answers Regarding …

FHA Mortgagee Letter 2020-19 Extends Foreclosure and Eviction Moratorium in Mortgagee Letter 2020-13

In Client and Friends Memos, FHA by BMG Memorandum

On June 17, 2020, the Federal Housing Administration (FHA) issued Mortgagee Letter 2020-19 (ML 2020-19). ML 2020-19 extends the foreclosure and eviction moratoriums originally issued in Mortgagee Letter 2020-04 and extended in Mortgagee Letter 2020-13 for borrowers with FHA-insured Single Family mortgages covered under the Coronavirus Relief, and Economic Security (CARES) Act for an additional period through August 31, 2020. …

OCC Issues Final Rule Amending OCC Regulations to Negate Interest Rate Transfer Decision in Madden v. Midland Funding, LLC, 786 F.3d 246 (2d Cir. 2015)

In Client and Friends Memos by BMG Memorandum

By final rule effective August 3, 2020, the Office of the Comptroller of the Currency (OCC) negates the decision in Madden v. Midland Funding, LLC, 786 F.3d 246 (2d Cir. 2015), in which the Second Circuit held that a purchaser of a loan originated by a national bank could not charge interest at the rate permissible for the bank if …

FHA Mortgagee Letters 2020-13 and 2020-14 Extend Foreclosure and Eviction Moratorium (ML 2020-13) and Remote Work Flexibilities for Lenders and Appraisers (ML 2020-14)

In Client and Friends Memos, FHA by BMG Memorandum

On May 14, 2020, the Federal Housing Administration (FHA) issued Mortgagee Letter 2020-13 (ML 2020-13) and Mortgagee Letter 2020-14 (ML 2020-14). ML 2020-13 extends the foreclosure and eviction moratoriums originally issued in Mortgagee Letter 2020-04 for borrowers with FHA-insured Single Family mortgages covered under the Coronavirus Relief, and Economic Security (CARES) Act for an additional period through June 30, 2020, …

HMDA Regulation C Final Rule Amends Permanent Institutional and Transactional Coverage Thresholds

In Client and Friends Memos by BMG Memorandum

In the May 12, 2020, Federal Register (85 FR 28364, click here), the Consumer Financial Protection Bureau (CFPB) issued a final rule amending Regulation C (12 CFR part 1003), which implements the Home Mortgage Disclosure Act (HMDA). The final rule permanently increases the institutional and transactional coverage thresholds for reporting data about closed-end mortgage loans from 25 to 100 closed-end …

Interim Rule Amends NCUA Regulations to Temporarily Defer Appraisal and Written Estimate of Market Value Requirements for Certain Real Estate Transactions

In Client and Friends Memos by BMG Memorandum

In the April 21, 2020, Federal Register (85 FR 22014), the National Credit Union Administration (NCUA) adopted an interim final rule deferring the regulatory requirement for credit unions to obtain an appraisal or written estimate of market value for up to 120 days following the closing of a transaction for residential and commercial real estate transactions, excluding transactions for acquisition, …

Interim Rule Amends Federal Regulations to Temporarily Defer Appraisal and Evaluation Requirements for Certain Real Estate Transactions

In Client and Friends Memos by BMG Memorandum

In the April 17, 2020, Federal Register (85 FR 21312, click here), the Office of the Comptroller of the Currency, Treasury (OCC), Board of Governors of the Federal Reserve System (FRB), and the Federal Deposit Insurance Corporation (FDIC) adopted an interim final rule deferring the above agencies’ (collectively, the agencies) regulatory requirements for regulated institutions to obtain an appraisal or …