H. Joshua Kotin

Mar 6, 2024 | mondaq.com | H. Joshua Kotin |Michelle Rogers

On February 23, 2024, the Consumer Financial Protection Bureau (CFPB) made public an order establishing supervisory authority over a nonbank installment lender on the basis the institution poses risks to consumers. The order gives insight into the procedural aspects of the CFPB's exercise of this never-before-used authority – and the standards it might use to assess whether an institution poses risk to consumers, and therefore warrants ongoing supervision.

Feb 28, 2024 | mondaq.com | H. Joshua Kotin |Michelle Rogers

On February 12, 2024, the Federal Financial Institutions Examination Council (FFIEC) issued a concise statement on Examination Principles Related to Valuation Discrimination and Bias in Residential Lending. Although the document is styled as a statement of principles, it sets forth a compliance management framework for which banks, credit unions and mortgage lenders will be examined as to their oversight of appraisals and property valuations.

Nov 14, 2023 | mondaq.com | H. Joshua Kotin

On November 2, 2023, the Consumer Financial Protection Bureau (CFPB) issued a survey on state Community Reinvestment Acts (CRAs) aimed at informing states without CRAs about actions they could take to promote lending and investment in communities of color. In connection with the release, the bureau highlighted the explosive growth of mortgage lending by nonbanks as compared to banks—only the latter of which are covered by the federal Community Reinvestment Act.