Posts tagged ‘TILA’

How Square’s Purchase of Afterpay May Impact Your CU

The announcement that Square will purchase Afterpay for a mere $29 B is more than just another business story. Look under the hood and the transaction shows: how the payment space is fundamentally changing; the way transactions are executed; raises questions about the continued utility of the existing regulatory framework; and demonstrates yet again that financial institutions, which do nothing more than hold money and keep consumer’s income safe, are becoming increasingly minor cogs in consumer financial transactions.

First, what is Afterpay and what does it do? As I explained in this blog, Afterpay is an online payment platform started in Australia less than a decade ago which specializes in facilitating buy-now, pay-later transactions. Merchants agree to pay a fee to facilitate in-store purchases; consumers agree to repay the purchase with a limited number of payments; and Afterpay agrees to purchase the sales installment contract.

What’s so clever about this arrangement? Merchants get their money free and clear even if the fee they pay seems an awful lot like an interchange fee. What’s in it for the consumer? Apparently, Millennials really do hate debt. Good for them. The installment plans give them reasonable payment flexibility without using a credit card. Afterpay avoids the federal disclosure requirements mandated by the Truth In Lending Act (TILA) by limiting payment to four installments. A fifth installment would trigger TILA. The model also gives Afterpay a huge volume of retail installment contracts to buy and sell. You can easily imagine these things packaged into securities.

Square is a more traditional peer-to-peer payment platform started way back in the teens of this century. It specializes in giving merchants easy access to payment platforms and of course, getting a piece of each transaction.

The amazing thing about all these developments is how little these entities are regulated. Afterpay did enter into a consent decree with California in which it agreed to comply with state level license requirements for retail lending. But one states licensing requirements do not level the playing field.

One more thought.  Recently the Biden Administration announced it was going to take a more aggressive view of mergers under our antitrust laws. In reviewing this proposed purchase, I’m assuming the Justice Department will be asking itself whether the real purpose of this transaction by Square is to buy up a potential competitor in a payment space it ultimately hopes to monopolize, as opposed to helping consumers by bringing resources to a company whose unique payment model expands choices for consumers.  Call me cynical, but I have my doubts.

August 3, 2021 at 10:34 am Leave a comment

Juneteenth Creates Compliance Glitch For Mortgage Lenders

The passage of legislation making Juneteenth a national holiday resulted in a compliance glitch which the CFPB could, and hopefully will, fix as early as today.

This issue sent me back to the preamble to the 2013 final TRID regulations. As the CFPB explained, neither RESPA nor TILA defines the term “business day.” As a result, for reasons that have never been clear to me, Regulation X which implements RESPA and Regulation Z which implements TILA contain separate definitions of a business day.

Most importantly, Regulation Z applies a definition of business days which includes calendar days except Sunday and legal public holidays specified in § 5 USC 6103. This is the section of law amended by Congress last week. As a result, from a strict compliance standpoint, June 19th was a national holiday and not a business day for disclosure purposes. This means that your credit union runs the risk of making loans that are out of compliance with federal regulations.

Yours truly is hopeful that common sense will prevail. Hopefully the CFPB will issue guidance clarifying that for purposes of complying with federal regulations. Lenders will not be deemed to be out of compliance for counting Juneteenth as a business day in 2021.

NY to Release Diversity and Inclusion Document to State Regulated Institutions

The Department of Financial Services will shortly release a memorandum to state chartered institutions explaining the department’s expectations as it relates to diversity and inclusion in the workplace. This publication is similar to one issued last October related to climate change initiatives. Its purpose is not to impose specific mandates at this time but to begin a discussion about the requirements that should be imposed on banks, credit unions, and mortgage lenders. When it comes to the efforts they are making to bring more diversity to middle and upper management. Stay tuned.

June 21, 2021 at 9:33 am Leave a comment

DFS Flexes Its Cybersecurity Muscles

Few regulatory initiatives in New York State created as much agita for state licensed and chartered institutions as New York’s Department Of Financial Services’ (DFS) Part 23 NYCRR 500 Cybersecurity Regulation.  The regulation mandates that regulated entities have a robust cybersecurity framework coupled with stiff penalties for violations.

Yesterday, the Department demonstrated just how serious it is about enforcing these regulations. It announced that it was bringing charges against First American Title Insurance Company for its alleged violations of these regulations following discovery of a massive data breach.  First American has indicated that it will fight these charges giving the rest of us an armchair view of litigation which could shape how aggressively states like New York and California will be able to enforce cybersecurity protections in the absence of Federal preemption.

I’ve been surprised by the lack of attention the breach of First American Title’s databases has received.  In May 2019 the KrebsOnSecurity blog broke the news that the California based Fortune 500 Company, which provides title insurance and closing services, could be compromised by anyone who knew the company URL for a valid document at its web site.  They could view other documents just by modifying a single digit in the link.  Considering the amount of non-public personally identifiable information available on the website, this is troubling news for tens of millions of Americans who had a real estate transaction involving the company as far back as 2003.

The specific allegations should be read by your Chief Information Security Officer.  The major thrust of DFS’ complaint is that its staff did not recognize the seriousness of the vulnerability or take prompt action to solve the problem once it was discovered.

The regulatory action also underscores one of the key differences between a company’s obligations under these regulations and its legal liability under a lawsuit brought by impacted consumers.  It’s much easier for regulators to successfully sue a company under New York’s regulations because New York does not have to prove that the breach harmed specific individuals.

TILA Compliance Thresholds Adjusted  

It’s that time of year again. In case you missed it, I did, on July 17th the CFPB issued its annual inflation-adjusted thresholds for compliance with various requirements mandated by Regulation Z and the Truth In Lending Act (TILA).  These changes take effect in 2021.

On that note, enjoy watching the Yankee game tonight. Although everyone is making a bid deal about playing in empty stadiums, as a life-long Islander fan who went to hundreds of games over a 20 year period when the team was so bad that the Nassau Coliseum was dubbed “the Nassau Mausoleum”, I’m kind of use to watching games with no one around.  These are strange times we’re living in.

July 23, 2020 at 9:16 am Leave a comment

CFPB Clarifies TRID Liability

 

Well, I’m back for another fun-filled year trying to help you stay up-to-date on the issues that could most affect your credit union.  If, like your faithful blogger, you have spent a good chunk of the last week and a half engaged in pursuits that have little if anything to do with banking, here is a quick look at an important development you may have missed.

On December 29, the CFPB offered its opinion regarding the increased liability mortgage lenders face as a result of the “Know Before You Owe” mortgage disclosure rule that took effect in October in response to a letter from the Mortgage Bankers’ Association.  In a nutshell, the Bureau does not believe that lenders face greater liability.  This is certainly one to keep in the file.  Dodd-Frank mandated that homeowner disclosures required by the Truth in Lending Act and RESPA be combined into a single regulatory framework.  Since RESPA and TILA have historically imposed different penalties for compliance failures, lenders have been justifiably concerned about how much liability they face when they make a mistake implementing this new regulation.

Among the key points from the Bureau are “as a general matter” legal liability will be based on the accuracy of final closing disclosures and not on initial loan estimates.    According to the Bureau, this means that “a corrected closing disclosure could, in many cases” forestall private liability.

In response to concerns that the regulation has made it more difficult to sell mortgages in the secondary market, the Bureau stresses that if investors are rejecting loans based on formatting “and other minor errors,” they are doing so for reasons unrelated to potential liability.

While the Bureau’s clarifications are welcome, the issues raised by concerned lenders, including credit unions, will ultimately be resolved by the Courts.  In other words, while the CFPB’s interpretation of Dodd-Frank may provide persuasive authority, it is far from the final word on the issue.

On that note, welcome back.

 

January 4, 2016 at 8:20 am 1 comment

Supreme Court Rules for Consumers in TILA Case

The Supreme Court decided the first of a series of cases this year that may impact your credit union’s operations. In Jesinoski v. Countrywide Home Loans, Inc., the Court decided a narrow but important issue involving the right to rescind that has split the federal courts.

As you undoubtedly know, the Truth in Lending Act mandates that lenders provide consumers notice of a right to rescind certain mortgage transactions, which grants them three days to rescind the transaction. This means that the member who gets cold feet about taking out a home equity loan to finance his dream addition has three business days to notify you that he wants to opt out. The right of rescission does not apply to home purchases.

The statute provides that a consumer may exercise the right to rescind until midnight of the third business day following delivery of the notice. It also provides that in the event that notice of the right to rescind has not been provided, a consumer has “three years after consummation” to rescind the loan. In the case decided by the Court, our homeowners took out a $635,000 loan. They were not given the notice of the right to rescind. They subsequently waited exactly three years before informing the lender that they wanted to rescind the loan. The bank argued, and the Eighth Circuit agreed, that the homeowners were out of luck. The lower court concluded that the failure to provide notice of the right to rescind gave homeowners the right to commence a lawsuit within three years of consummation.

The homeowners appealed and the Supreme Court ruled in their favor. In the unanimous and wonderfully concise opinion written by Justice Scalia, the Supreme Court concluded yesterday that the plain language of the Truth in Lending Act “leaves no doubt that rescission is effected when the borrower notifies the creditor of his intention to rescind. It follows that, so long as the borrower notifies within three years after the transaction is consummated, his rescission is timely. The statute does not also require him to sue within three years.”

A couple of quick thoughts about this case. Obviously, the situation that Countrywide found itself in can be easily avoided by your credit union provided you have the procedures in place to give consumers the necessary disclosures in a timely fashion. In those situations where you let the disclosures fall through the cracks, this decision does extend the amount of time a lawsuit requesting the right to rescind is hanging over your head. Finally, the Court’s ruling underscores yet again that for all its regulatory complexity, TILA is at its core a federal disclosure statute. If you have the proper disclosure procedures in place, there is very little TILA will prevent you from doing. If you don’t, Congress and the courts have little sympathy for you.

Incidentally, this is why it is so important to keep track of what disclosures your vendors are sending out on your behalf, and when they are being sent.

January 14, 2015 at 8:43 am Leave a comment

In defense of the CFPB

 

In today’s blog I come not to criticize the CFPB, but to praise it.

Earlier this week, it proposed further amendments to its Integrated Disclosure requirements that take effect August 2015. These Dodd-Frank mandated amendments replace the erstwhile Good Faith Estimate with a Loan Estimate.  The amendments proposed this week are not big deals. They are tweaks that won’t keep you from cursing Dodd- Frank; but the very fact that the amendments are being proposed speaks volumes about the good side of the CFPB.

Does the CFPB have too much power? You bet It does. Does the Bureau That Never Sleeps pay too little attention to the burdens it is imposing on industry? Absolutely. But a good regulator is like a good umpire: You might disagree with the dimensions of his strike zone but a good umpire like a good regulator approaches regulations and their enforcement in a consistent manner so that everyone knows when they have missed the strike zone. By this standard, the CFPB is doing a great job.

Under the integrated disclosure requirements that take effect in August 2015-remember, they combine the separate disclosures currently mandated under TILA and RESPA-lenders are permitted to redisclose Loan Estimates when a mortgage interest rate is locked. For the redisclosure to be valid, the regulation currently provides that it has to be made “on the day the interest rate is locked.”

When the integrated mortgage proposal was put forward the rate-lock provision did not get all that much attention; the Bureau assumed that requiring same day redisclosure was not a big deal for lenders because they knew the rate they were going to charge. The CFPB could have obstinately refused to reconsider the regulation after it issued them in final form. Instead, it continued to listen to affected industry participants, was convinced that the requirement would be more difficult for lenders to comply with than it originally assumed and is now proposing to amend the final regulation to authorize a revised Loan Estimate to be issued no later than the next business day after the rate is locked.

A second proposed revision announced this week is targeted towards new construction loans. It permits creditors who reasonably expect settlements to occur more than 60 calendar days after initial disclosures have been issued to state on Loan Estimates that they may issue new disclosures.

The political environment is so weighed down with justified cynicism that  the CFPB often catches the institutions it regulates off guard by remaining true to its mission. Before it changes a regulation its primary question is: will the change  benefit, or at least not diminish, consumer protections? For example, in the preamble to these proposed amendments the CFPB argues that giving lenders until the next business day to redisclose loan estimates will benefit consumers by giving them more time to accept loan offers.

Then there is the intangible benefit of dealing with a regulator that writes and explains regulations more clearly than any other. You may not agree with its mortgage regulations but it has provided material designed to help even the smallest lender comply with them.

I apologize but I am still thinking about the Kansas City Royals crashing into over and under walls to make catches and I can’t get baseball metaphors out of my head. The bottom line is that the CFPB has a consistent strike zone. Its overriding mission is to protect consumers. When commenting on one of its proposals, it is incumbent on industry participants to quantify regulatory burdens with concrete operational examples and to suggest alternatives that will not diminish consumer protections. I will continue to disagree with the parameters of the Bureau’s strike zone but also give it much-deserved credit for the consistency and diligence with which it is carrying out its mission.   Here is a link to the proposal which also includes other technical changes..

http://www.consumerfinance.gov/blog/know-before-you-owe-proposed-updates-tila-respa-final-rule/

October 16, 2014 at 10:08 am Leave a comment

Military Misfires on Consumer Protection

Today’s blog provides a good example of how well-intentioned people can end up doing more harm than good.  The Department of Defense recently proposed expanding the coverage of consumer protection laws that currently apply to pay-day loans, refund anticipation loans and vehicle title loans to most consumer loans covered by the Truth in Lending Act. It would not apply to loans to purchase a vehicle or a home.  If the DOD isn’t careful, it will dry up the swamp of creditors who prey on our service members, which of course is a good thing, but do so in a way that will make it more difficult for members of the armed forces to get access to consumer credit, especially from credit unions.  Here’s why.

Back in 2007, responding to wide spread reports of predatory lending activities targeting the military, Congress passed the Military Lending Act.  The Act empowered the Department of Defense to define and regulate consumer credit products provided to active duty members of the armed forces and their dependents.  It gave the military wide discretion in determining what products would be subject to the enhanced regulatory restrictions.  Under the regulations promulgated by the DOD, a 36% interest rate cap was placed on refund anticipation loans, pay-day loans, and vehicle title loans.  In addition, the cap is calculated based on the Military Annual Percentage Rate (MAPR), which is succinctly summarized by the CFPB to include interest, fees, credit service charges, credit renewal charges, credit insurance premiums and other fees related to credit products sold in connection with the loan.  Creditors selling these loans have to provide enhanced disclosures, as well as take affirmative steps to identify eligible consumers.

At the time the legislation was enacted, credit unions and other financial institutions were concerned that if regulations were written too broadly, they would require the wide-spread adoption of two types of consumer loan products:  one for the military and one for civilians.  However, the final regulations were narrow enough in scope so that they didn’t impact the vast majority of credit unions, most of which would have no desire to offer these types of products in the first place, even if located in states where they were permitted to do so.

The statute as it has been implemented by the DOD made sense, at least until last Friday.  The DOD is proposing regulations that would expand the definition of products covered under the statute to include credit cards and other consumer loans covered under the Truth in Lending Act.  As a result, credit cards offered to members of the military and their dependents would be subject to a 36% cap calculated by a refined MAPR.  To be fair, the military recognizes that a poorly drafted regulation runs the risk of denying mainstream credit to members of the armed forces, so it is refining the MAPR to, for example, exclude customary and reasonable fees.  But the calculation of an MAPR would still differ for members of the military and civilians.  Furthermore, by expanding the reach of the MLA to most consumer loans except home mortgages and car loans, the military will make it more difficult for credit unions to provide legitimate loans to service members.

In fact, the proposal is such a bad idea that NCUA took the highly unusual step of issuing a statement critical of the proposal the same day it was announced.  It pointed out that NCUA’s pay-day lending alternative was designed specifically to fit within the Department’s existing regulations.

Current NCUA regulations allow federal credit unions to offer payday alternative loans with an interest rate of up to 28 percent and an application fee of up to $20. Under the Military Lending Act regulations, consumer credit to covered borrowers is subject to a 36 percent cap on the military annual percentage rate, or military APR, which includes application fees. If these regulations are revised to cover payday alternative loans, the rate and fee for many payday alternative loans would be higher than the military APR cap.

Conversely, our good friends at the bureau that never sleeps, the CFPB, thinks the Department’s proposal is a swell idea.  Proponents of the DOD’s approach point out that it is extremely easy to avoid compliance with the MLA.  For example, a loan with a 91-day repayment period isn’t classified as a pay-day loan under the regulations, but a 90-day loan could be.  They argue that by expanding the size of the jurisdictional net, it will be easier to catch those creditors who prey on members of our armed forces.  The problem with larger fishing nets, of course, is that they scoop up everything in their wake, including fish that no one wants to catch in the first place.

Perhaps DOD should consider expanding the definition of the existing products covered under the MLA rather than grabbing everything into its jurisdiction.  Another alternative, which it notes in the preamble that it is open to considering, is to exempt certain types of institutions from coverage of the expanded regulations.  Considering that federal credit unions are already subject to an interest rate cap on loans and that the vast majority of credit unions are places that members of the military looking for a fair deal should be encouraged to patronize, an exemption makes sense to me.

At ease.

October 1, 2014 at 8:30 am 1 comment

What Is An Application? Does Anyone Really Care?

The answer to the first question is that our good friends at the CFPB have provided us with a definition of application for purposes of sending out mortgage disclosures that takes effect next August.  The answer to the second question is if your credit union offers mortgages, then you should.

First, some background.  Who could forget last December when the CFPB unleashed a host of Dodd-Frank mandated regulations reshaping the regulatory framework for mortgages.  I know you all now know what a QM mortgage is, but you’re not quite done yet.  The CFPB also released regulations that integrated mortgage disclosures mandated by both the Truth in Lending Act and RESPA.  Starting next August, the GFE and early TIL will be replaced with a single document titled the Loan Estimate.  If you were like me, you looked at the 900 pages of this proposal, noted that the effective date wasn’t until August of 2015 and put it at the bottom of your to-do list.  Now, it is time to get focused.  There a lots of operational decisions that need to be made beyond simply calling up your vendor and finding out if it will be ready to send out the new disclosures.

One of the most basic and important changes made by the CFPB has to do with the definition of application.  Under existing law, lenders have to give a borrower a good faith estimate of the mortgage costs within three business days of receiving a mortgage application.  Under existing regulations, an application is received when a lender has the borrower’s name, monthly income, social security number, the property address, an estimate of the value of the property, the requested mortgage loan and — here’s the key part — “any other information deemed necessary by the loan originator.”  The catch-all provision is crucial since it gives lenders the ability to provide general loan estimates without being bound by a GFE.

Flash forward to August of next year and that catch-all provision will no longer be included in the definition of application.  Instead, any time a credit union receives the other six pieces of information, the application has been received and the GFE clock starts ticking.  Now, many lenders use more than these six pieces of information in making lending determinations.  So what are they going to do?

First, a GFE is not the same as making a mortgage determination.  If, as verifying information comes in, you determine the applicant isn’t qualified for a mortgage loan, you don’t have to give him one.  Second, you can continue to prequalify members without requesting the six pieces of information.

But there is a more subtle way in which the CFPB is still allowing lenders flexibility in terms of when an application becomes an application.  As the CFPB explains in the preamble to the regulation, “the definition of an application may not have a significant impact on a creditor’s ability to delay provision of a Loan Estimate, because the creditor can simply sequence its application process to delay collection of some or all of the six pieces of information that would make up the definition of an application.”  For example, let’s say there are two additional pieces of information beyond the six in the definition that you have to specifically ask for before providing a GFE.  The CFPB is allowing institutions to ask for those two pieces of information before the other six.  You can find this quote at the bottom of page 79766 of the Final Regulation.  I would actually save the specific page in my mortgage file.  The ability to sequence isn’t all that clear from the language of the regulation or its official interpretation.

This is just one example of operational questions that have to be considered by your credit union and then communicated to your vendor.  There are several other key compliance issues impacted by this regulation and with regulators in summer mode, I will be passing on tidbits in the days and weeks to come.  I know this is not exciting stuff, but it’s time to stop procrastinating.

 

June 30, 2014 at 8:39 am 1 comment

The Right of Rescission and its Limits

Just about everyone knows that when they take out a home equity loan to remodel the kitchen, they have three business days to rescind the transaction.  This right comes to us courtesy of 15 USC 1635(a) and its corresponding regulations at 12 CFR 1026.23(a)(2).  It applies to any individual who receives consumer credit in exchange for a security interest in his or her principle dwelling.  This provision occasionally scares the bejebies out of credit unions because if its notice requirements aren’t followed, the homeowner has three years to rescind the loan.

This sounds like a big deal but a recent decision by the federal Court of Appeals Seventh Circuit underscores that the right of rescission has its limits.  The ruling is consistent with what New York’s federal courts have said about the issue and the decision is worth filing away if and when a member defaults on a home loan.

Iroanyah v. Bank of America involved homeowners who took out two mortgages against their home.  As required by the Truth in Lending Act, they were given a disclosure statement explaining the repayment schedule, including the number of payments, the amount due for each loan, and the due dates for the first and last payments.  However, the disclosures did not include the date on which each payment was due, nor the frequency with which payments were to be made.  As my wife just pointed out, this seems like a fairy significant oversight, and indeed it was.

When the homeowners stopped making payments and the evil bank moved to foreclose on the property, the homeowners argued, and the court agreed, that their right of rescission had been violated.  At this point of the decision, the homeowners probably thought it was time to uncork the champagne.

But then the Seventh Circuit explained that even though the Truth in Lending Act requires a creditor to release its security interest and return all money paid in connection with a transaction (12 CFR 226.23(d)(4)), the courts have the authority to condition the release of a lien on the borrowers repayment of any unpaid loan proceeds already advanced to the borrower.  In other words, the right of rescission doesn’t provide a windfall to the borrower who takes out a consumer loan.  Instead, it puts the borrower back where he would have been had the loan never been made.  As the Court noted, “TILA does not give borrowers the right to rescind their own obligations without also making the lenders whole.”  The exact repayment terms are within the discretion of a court to fashion.

One other interesting aspect of this case is worth noting.  When the right of rescission notices are not properly provided, homeowners have three years as opposed to three days to rescind the transaction.  However, the homeowner still has only one year from the date of the violation to sue for damages resulting from this violation.

Strip away the legal niceties and if you ever find yourself facing a potential violation of the right to rescind, don’t panic.  Once you start reading the way the statute has been interpreted, its bark is much worse than its bite.

 

 

 

June 5, 2014 at 8:45 am Leave a comment

On lawsuits and pixie dust

Good morning folks!  There is a lot of little news I want to get to, but I can’t resist a few comments on the lawsuit that was filed by a community bank in Texas challenging the Constitutionality of the CFPB.  I haven’t been able to read the complaint yet, but one summary I read suggested that the lawsuit also challenges the legality of President Obama’s recess appointment of Richard Cordray as its Acting Director. 

Listen, I can be as critical of the CFPB as anyone, but one of the reasons I’ve always been on the conservative side of judicial issues is because I believe the more judicial restraint you have, the more issues you leave to the elected branches of government.  Like it or not, Congress passed Dodd-Frank.  Congress did give the Bureau enormous powers, but the powers are no greater than those previously exercised by the bureaucracies whose powers it subsumed and there is a mechanism for its regulations to be overturned if enough other regulators believe they are inappropriate.  Let’s face it, the CFPB is here to stay.  Even if the Republicans managed to take over the Senate, they won’t have the votes needed to pass any legislation dissolving it.  If people don’t like the CFPB, they should take it out on their legislators instead of running to the courthouse.  By the way, this is not to say that there aren’t some legitimate issues surrounding the legality of recess appointments, but the Bureau itself is here to stay.

CFPB Updates Progress on Mortgage Disclosures

Not everything that the CFPB wants to do is bad for business.  Yesterday at a House Committee meeting CFPB’s ubiquitous Deputy Director Raj Date provided an update on the Bureau’s efforts to consolidate Truth in Lending and RESPA mortgage disclosures.  A proposed regulation will be out by July 21, but as many of you probably already know, the CFPB has gone through several rounds of testing of proposed new forms.  There is no area of regulation that better exemplifies the need for regulatory streamlining than mortgage disclosures.  As Mr. Date himself commented “[t]he information on these forms is overlapping and the language is inconsistent. Not surprisingly, consumers often find the forms to be confusing. It is also not surprising that lenders and settlement agents find the forms burdensome to provide and explain.”  If the Bureau does a good job with this regulation it could go a long way toward showing people the value of having a CFPB with the authority to consolidate duplicative regulations.

Moody’s Downgrades Bank Debt

Moody’s yesterday downgraded the credit ratings of the nation’s largest banks, including Goldman Sachs, JP Morgan-Chase, and Morgan Stanley.  The downgrade had been rumored for months so its practical impact is somewhat muted.  Still, it’s another embarrassing blow to the banking industry. 

Joint Guidance on Assistance for Servicemembers with Permanent Change of Station Orders Released

Federal regulators, including the NCUA, released a guidance on efforts that financial institutions should take in assisting members of the armed services subject to mandatory transfer orders.  The guidance points out that servicers should work with affected individuals to make sure that they are aware of government programs that may assist them.

June 22, 2012 at 8:04 am Leave a comment


Authored By:

Henry Meier, Esq., Senior Vice President, General Counsel, New York Credit Union Association.

The views Henry expresses are Henry’s alone and do not necessarily reflect the views of the Association. In addition, although Henry strives to give his readers useful and accurate information on a broad range of subjects, many of which involve legal disputes, his views are not a substitute for legal advise from retained counsel.

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