We look at the practices found to be unlawful by CFPB examiners in these markets, discuss what the findings signal for future scrutiny of these markets by the “new CFPB”, and share practical takeaways for companies operating in these markets. Issues highlighted in our conversation include the CFPB’s findings regarding “unreliable furnishers,” furnisher handling of “frivolous or irrelevant” disputes, interest accrual on debts in collection, and mortgage servicer consideration of private mortgage insurance termination dates when estimating disbursements in an annual escrow analysis.
Ballard Spahr Senior Counsel Alan Kaplinsky hosts the conversation, joined by Chris Willis, Co-Chair of the firm’s Consumer Financial Services Group, and Reid Herlihy, a partner in the firm’s Mortgage Banking Group.
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