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Unwinding the COVID-19 concessions for 'secret CECL'

Unwinding the COVID-19 concessions for 'secret CECL'
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Nutter Bank Report: April 2021 | Nutter McClennen & Fish LLP


Headlines
CFPB Issues Interim Final Rule to Support CDC Moratorium on Evictions
FEMA Announces Changes to National Flood Insurance Program Pricing
Proposed Rule Would Establish Mandatory Terms for Tax Allocation Agreements
Other Developments: Paycheck Protection Program and Qualified Mortgages
1. CFPB Takes Steps to Avoid a Possible Wave of Home Mortgage Loan Foreclosures
The CFPB has issued guidance to mortgage servicers, including banks that service mortgage loans for third-party noteholders, that the CFPB expects servicers to dedicate sufficient resources and staff to reduce avoidable foreclosures in coming months. According to the guidance issued on April 1, Compliance Bulletin 2021-02, the CFPB believes consumer home mortgage borrowers needing loss mitigation assistance as the COVID-19 foreclosure moratoriums and forbearances end will face heightened risks of foreclosure. The CFPB’s guidance urges mortgage servicers to dedicate resources and staff to ....

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CFPB Bites of the Month - April Top 10 | Hudson Cook, LLP


Each month, we host a 30-minute
webinar outlining the month s key announcements and takeaways from the Consumer Financial Protection Bureau (CFPB) for financial services providers to consider. In this month s article, we share some of our top bites covered during the April 21 webinar.
So what happened at the CFPB in the past month?
Bite #10 - The CFPB submitted its FDCPA report to Congress and took various FDCPA enforcement actions
The CFPB released the 2020 annual report to Congress on the administration of the Fair Debt Collection Practices Act (FDCPA). Among other highlights, the report notes the following CFPB accomplishments:
Identified several issues that raise the risk of consumer harm during the COVID-19 pandemic through its supervisory Prioritized Assessments; ....

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CFPB Announces Foreclosure Restriction And Additional Loss Mitigation Requirements - Finance and Banking


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On April 5, the Consumer Financial Protection Bureau
( CFPB ) proposed amendments to Regulation X with the
effect of preventing foreclosure on certain residential mortgage
loans until January 1, 2022.
1  With a proposed effective
date of August 31, 2021, this action would apply not only to
federally backed mortgage loans, but to all mortgage loans secured
by a property that is a borrower s principal residence
2 -
including those held in private trusts and on lender balance
sheets.  On April 3, the CFPB and other governmental agencies
charged with overseeing mortgage servicers issued a joint statement ....

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