New York challenges OCC’s decision to grant fintech charter applications

By Thomas G. Wolfe, J.D.

The Superintendent of the New York State Department of Financial Services (NYDFS) has filed a complaint seeking declaratory and injunctive relief against the Office of the Comptroller of the Currency in connection with the OCC’s July 2018 decision (Fintech Charter Decision) to immediately begin accepting applications from, and grant special-purpose national bank charters to, financial technology (fintech) companies—including companies that do not accept deposits. The NYDFS’s complaint, which was filed on Sept. 14, 2018, in the U.S. District Court for the Southern District of New York (Vullo v. Office of the Comptroller of the Currency, Docket No. 18-cv-8377), contends that the Fintech Charter Decision exceeds the OCC’s authority under the National Bank Act and violates the Tenth Amendment to the U.S. Constitution. In addition, the NYDFS maintains that the OCC’s regulation covering special-purpose national banks is null and void because the agency exceeded its authority by defining the “business of banking” to include non-depository institutions.

Previously, in May 2017, the NYDFS sued the OCC in the same federal district court to block the agency from creating new special-purpose fintech charters. However, the court later determined that the New York regulator’s challenge was premature and failed on standing and ripeness grounds because the OCC had not yet reached a final decision on whether to grant special-purpose national bank charters to fintech companies.

Now, the landscape for special-purpose national bank charters has changed with the OCC’s Fintech Charter Decision. Also, a banking start-up, Varo Money, Inc., recently announced that it was granted “preliminary approval” of its application for a national bank charter by the OCC, pending Varo’s completion of standard conditions.

NYDFS complaint. Generally, the September 2018 complaint by the NYDFS characterizes the OCC’s Fintech Charter Decision not only as “lawless, ill-conceived, and destabilizing of financial markets that are properly and most effectively regulated by New York State,” but also as placing New York financial consumers “at great risk of exploitation by federally-chartered entities improperly insulated from New York law.” According to the NYDFS, the OCC’s special-purpose charters in the fintech field would impose preemptive powers over state law and state interests to the detriment of New York consumers and businesses.

More specifically, in asserting that the OCC’s Fintech Charter Decision is “legally indefensible” because it grossly exceeds the agency’s statutory authority under the “Business of Banking” clause of the National Bank Act (12 U.S.C. §24), the NYDFS’s complaint maintains that:

• the lack of any authorization by Congress for the OCC’s Fintech Charter Decision “indisputably deprives preemptive effect” to the OCC’s actions;
• the OCC impermissibly redefined the scope of the “business of banking” definition in its promulgated regulation (12 CFR §5.20(e));
• federal courts have previously struck down the OCC’s administrative efforts to authorize national banks that do not accept deposits;
• contrary to the clear intent of Congress, the OCC is empowering itself to charter non-depository institutions; and
• because New York is a global financial center and is “effectively a global financial regulator,” the Fintech Charter Decision will severely undermine New York’s ability to protect its financial markets, businesses, and residents.

Relief requested. In keeping with the allegations in its complaint that the OCC’s Fintech Charter Decision and the OCC’s regulation (12 CFR §5.20(e)) exceed the federal agency’s proper statutory authority, the NYDFS is requesting that the court declare both the Fintech Charter Decision and the OCC regulation unlawful, set them aside, and prevent the OCC and Comptroller Joseph Otting from taking any further actions to implement their respective provisions. Further, the NYDFS asks the court to declare the Fintech Charter Decision null and void because it violates the Tenth Amendment’s constitutional protections of state rights in connection with New York’s “police power” to regulate financial services and products.

 

For more information about actions taken by state regulators affecting the financial services industry, subscribe to the Banking and Finance Law Daily.

Fed amends liability provisions of check collection rule

By Andrew A. Turner, J.D.

The Federal Reserve Board has amended provisions of Reg. CC—Availability of Funds and Collection of Checks (12 CFR Part 229) that deal with situations in which there is a dispute about whether a check has been altered or was unauthorized and the original paper check is unavailable. Under the change, there will be a presumption that the check was altered or unauthorized if the dispute is between banks.

In today's check collection environment, original paper checks may be unavailable for inspection in certain disputes between banks. Unlike in prior court cases, where the paying bank received and destroyed the original check, the original check is typically truncated by the depositary bank or a collecting bank before it reaches the paying bank.

Presumption. The presumption of alteration applies to a dispute between banks where an electronic check or a substitute check was transferred between those banks. The Fed does not believe that limiting the application of the presumption to the transfer of electronic checks or substitute checks will create a material incentive for depositary banks or collecting banks to bypass the check imaging process and send forward a substantial number of original checks merely to preserve the presumption of alteration.

By mutual agreement, banks may vary the effect of the amendments' provisions. The presumption does not apply if it is contrary to another federal statute or regulation, such as the Treasury Department’s rules regarding U.S. Treasury checks.

The amendments become effective January 1, 2019.

For more information about Federal Reserve Board regulatory requirements, subscribe to the Banking and Finance Law Daily.

Zions bank is not systemically important, FSOC decides

By J. Preston Carter, J.D., LL.M.

The Financial Stability Oversight Council made a final decision to grant the appeal of ZB, N.A., under section 117 of the Dodd-Frank Act, ruling that it will not be treated as a designated nonbank financial company upon completion of its proposed merger with its parent bank holding company, Zions Bancorporation. The FSOC determined that there is not a significant risk that Zions could pose a threat to U.S. financial stability. The FSOC had made a proposed decision to grant the appeal on July 18, 2018.

ZB is a national bank headquartered in Salt Lake City, Utah, and a wholly owned subsidiary of Zions Bancorporation, a Utah corporation and a registered bank holding company and financial holding company. ZB has entered into an agreement with Zions Bancorporation pursuant to which Zions Bancorporation will merge with and into ZB. Upon the completion of the merger, ZB will succeed to all the assets and liabilities of Zions Bancorporation. ZB’s assets comprise 99.7 percent of the total consolidated assets of Zions Bancorporation, and ZB’s revenues account for 99.7 percent of the revenues of Zions Bancorporation. Zions has $66 billion of total consolidated assets and $59 billion of total liabilities.

If an entity subject to section 117 ceases to be a bank holding company, it will be treated as a nonbank financial company supervised by the Federal Reserve Board. That section applies to any entity that was a bank holding company with total consolidated assets of at least $50 billion as of Jan. 1, 2010, and received financial assistance under or participated in the Capital Purchase Plan established under the Troubled Asset Relief Program. Section 117 also provides that an entity may appeal its treatment as a designated nonbank financial company to the FSOC.

In its petition, ZB emphasized its relatively small size, lack of complexity, and low levels of interconnectedness compared to the U.S. global systemically important banks (G-SIBs) and other banks with $50 billion or more in total consolidated assets. ZB also described its role as a source of credit for low-income, minority, or underserved communities; its complexity and resolvability; assets under management; and the degree of regulatory scrutiny to which it will be subject after consummation of the merger.

According to Treasury Secretary Steven T. Mnuchin, "Zions engages in limited capital markets activities, presents minimal fire sale risks, uses a simple operational structure, and is subject to extensive regulation and supervision. The Council determined that there is not a significant risk that Zions could pose a threat to U.S. financial stability, and I am pleased that the Council used its authority to promote regulatory efficiency."

For more information about the Dodd-Frank Act and financial stability, subscribe to the Banking and Finance Law Daily.

Financial Services Committee marks up banking-related bills

By Colleen M. Svelnis, J.D.

The House of Representatives Financial Services Committee marked up and passed 12 bills out of committee for full House consideration. Chairman Jeb Hensarling (R-Texas) stated that the committee “took action today to provide critical reforms to the Federal Reserve.” According to Hensarling, “these bills help move us another step closer towards achieving our goals as a committee this Congress.”

H.R. 6743. Representative Blaine Luetkemeyer (R-Mo) issued a statement about one of the bills, the Leutkemeyer-sponsored H.R. 6743, the Consumer Information Notification Requirement Act, which was passed by a vote of 32-20. The bill would require any data security safeguards related to any entity providing insurance to be enforced by the state insurance authorities in the state in which the entity is “domiciled,” or in the case of an insurance agent, agency, or brokerage, by the authority in the state where the agent, agency, or brokerage has its “principal place of business.” Any notification requirements would also be enforced by the state insurance authority of any state in which customers of the insurance entity are affected by a data security breach. According to Leutkemeyer, “Nearly every week we discover new data breaches exposing the personal information of American consumers and today was our opportunity to take action to protect them. At some point there will be another major breach, and without a comprehensive solution our constituents will pay the price for our inaction.”

H.R. 6743 would also institute a statutory requirement that all financial institutions notify consumers in the event of a breach involving their personal information. Representative Randy Hultgren (R-Ill), a member of the Financial Services Committee, stated that “After last year’s data security breach at Equifax, it was clear that reform and a national standard are crucial to protect consumers.” Hultgren pointed out that the legislation would provide a national standard for financial institutions around data security and breach notification on behalf of consumers. It also establishes steps that covered entities need to take to notify regulators, law enforcement and victims after any breach exposing records of 5,000 or more consumers.

H.R. 6158. The Brokered Deposit Affiliate-Subsidiary Moderation Act of 2018 (H.R. 6158), introduced by Rep. Scott Tipton (R-Colo), was passed by a vote of 34-17. The bill would revise the definition of “deposit broker” under the Federal Deposit Insurance Act to exempt funds collected through an insured depository institution’s affiliate or subsidiaries of an insured depository institution. H.R. 5534, the Give Useful Information to Define Effective Compliance Act, introduced by Rep. Sean P. Duffy (R-Wis), was passed by a vote of 38-14. The bill would modify Title X of the Dodd-Frank Act so that the Consumer Financial Protection Bureau has clearly defined procedures on how to issue guidance, including guidance necessary to comply with the law, and provides a safe harbor for good faith reliance on guidance issued by the Bureau.

Additional bills. The committee also passed the following bills:

• H.R. 6751, the Banking Transparency for Sanctioned Persons Act of 2018, introduced by Rep. Mia Love (R-Utah), was passed by a vote of 48-0. The bill would require the Secretary of the Treasury to issue a semi-annual report to both the House Financial Services Committee and Senate Banking Committee regarding financial services provided to state sponsors of terrorism or certain sanctioned individuals. 
• H.R. 6737, the Protect Affordable Mortgages for Veterans Act of 2018, introduced by Rep. Lee Zeldin (R-NY), was passed by a vote of 49-0. The bill would amend the National Housing Act to provide a technical fix so that recently executed mortgage loans refinanced by the U.S. Department of Veterans Affairs Home Loans remain eligible for pooling in the Ginnie Mae securities. 
• H.R. 6729, the Empowering Financial Institutions to Fight Human Trafficking Act of 2018, introduced by Rep. Ann Wagner (R-Mo), passed by a vote of 44-5. The bill would instruct the Secretary of the Treasury to establish a mechanism for non-profit organizations to qualify for safe harbor when sharing specific information with financial institutions that facilitates their duties of customer due diligence and the reporting of suspicious activities relating to human trafficking. 
• H.R. 4753, the Federal Reserve Supervision Testimony Clarification Act, introduced by Rep.Frank Lucas (R-Okla), passed by a vote of 49-0. The bill would modify the Federal Reserve Act to require the Vice Chairman of the Board of Governors to fulfill the statutory requirement for semi-annual testimony of the Federal Reserve if the Vice Chairman for Supervision position is vacant. 
• H.R. 6745, the Access to Capital Creates Economic Strength and Supports Rural America Act, introduced by Rep. Sean P. Duffy (R-Wis), passed by a vote of 37-15. The bill would modify the Securities Exchange Act of 1934 to modify the shareholder threshold for registration defined under that Act. Additionally, the Securities and Exchange Commission would be required to submit a report to Congress regarding the impact of the bill three years after its enactment. 
• H.R. 2128, the Due Process Restoration Act of 2017, introduced by Rep. Warren Davidson (R-Ohio), was passed by a vote of 31-20. The bill would allow respondents in SEC enforcement cases to remove their proceedings out of the SEC’s administrative in-house tribunal to a federal district court. 
• H.R. 4758, the FOMC Policy Responsibility Act, introduced by Rep. Claudia Tenney (R-NY), was passed by a voice vote. The bill would modify the Federal Reserve Act to clarify that the Federal Open Market Committee is responsible for establishing interest rates on reserve balances. 
• H.R. 6021, the Small Business Audit Correction Act of 2018, introduced by Rep. French Hill (R-Ark), was passed by a vote of 36-16. The bill would modify the Sarbanes-Oxley Act of 2002 so that small, privately owned non-custodial brokers and dealers in good standing are no longer required to hire a Public Company Accounting Oversight Board-registered audit firm in order to meet the annual reporting obligations outlined by Title I of that Act. 
• H.R. 6741, the Federal Reserve Reform Act of 2018, introduced by Rep. Andy Barr (R-Ky), was passed by a vote of 30-21. The bill would require the FOMC to annually adopt a monetary policy strategy, as well as up to three reference rules that can increase policy transparency. 

Support from associations. Consumer Bankers Association expressed its support of H.R. 6743, H.R. 6158, and H.R. 5534, calling them “common sense bills which will help to increase consumer access to well-regulated financial service products.”

CBA stated that the comprehensive approach in H.R. 6743 “would better serve consumers by making it easier for financial institutions to adequately protect their customers from identity theft and account fraud.” With regard to H.R. 6158, CBA stated that the definition of deposit broker has not been updated since 1991 and since then the “vast technological innovation and new deposit account programs have entered the market changing the manner in which banks solicit deposits and interact with their customers.” Additionally, CBA stated that a “clear understanding of the rules of the road would help financial institutions meet statutory and regulatory intentions and ultimately better serve their customers” and that H.R.5534 “addresses these concerns by clearly defining guidance and requiring the BCFP to issue guidance necessary to carry out the law.”

American Bankers Association stated in a letter to the committee that its members “support reporting H.R. 6743 out of Committee so that Congress can take a step forward in enacting comprehensive data breach legislation.” H.R. 6743 would institute uniform consumer notification standards and would preempt state and local data protection and consumer notification standards.

State regulators oppose legislation. John W. Ryan, President and CEO of the Conference of State Bank Supervisors (CSBS), sent a letter to the Financial Services Committee leadership on behalf of the CSBS expressing CSBS opposition to both H.R. 6743 and H.R. 6741The letter expressed state regulators’ opposition to provisions in Section 7 of H.R. 6741 that “would impose a tax on state-chartered banks.” According to Ryan’s letter, Section 7 “calls on the Federal Reserve to assess new fees on state-chartered banks to cover the cost of the Federal Reserve’s bank supervision activities” without receiving any new supervisory benefit.

Ryan also notified the committee members that CSBS “firmly oppose H.R. 6743 for its attempt to preempt state data breach and privacy laws.” According to Ryan, H.R. 6743 undermines important sate consumer protections and “would preempt the authority of state regulators by preempting state laws that articulate when regulated entities are required to notify regulators and by preempting state authority to examine licensed nondepository financial institutions for compliance with data breach notification and other data security requirements.”

ConsumersUnion, the advocacy division of Consumer Reports, “strongly opposes” H.R. 6743, stating that the bill, if passed, “would further weaken existing protections for data held by financial institutions. This would leave consumers even more vulnerable to identity theft” According to a statement by the company, “the primary outcome of H.R. 6743 is to preempt useful, state-level data security and data breach notification protections—several of which were enacted in the wake of the Equifax data breach—and replace them with a lower standard of security.

For more information about legislative activity, subscribe to the Banking and Finance Law Daily.

State AGs to CFPB: Recognize, enforce ‘disparate impact’ liability under ECOA

By Thomas G. Wolfe, J.D.

In a letter to Consumer Financial Protection Bureau Acting Director Mick Mulvaney, a coalition of 14 state attorneys general expresses its “grave concerns” about statements that Mulvaney has reportedly made suggesting that the CFPB is “no longer allowed” to enforce the Equal Credit Opportunity Act’s prohibition against “disparate impact discrimination with regards to auto lending.” Underscoring the fact that state AGs share authority with the CFPB to enforce the Bureau’s regulations interpreting ECOA, and that many states have antidiscrimination statutes modeled on ECOA, the coalition urges the CFPB to reexamine its stance and recognize that ECOA “provides for disparate impact liability.” Moreover, in their Sept. 5, 2018, letter, the state AGs assert that they “will not hesitate to uphold the law” if the CFPB were to act in a manner deemed contrary to federal precedent, or if the Bureau fails to fulfill its “Congressional charge to ensure nondiscriminatory lending to the residents of our states.”

The coalition’s letter to Mulvaney is signed by the AGs from California, District of Columbia, Illinois, Maine, Maryland, Massachusetts, Minnesota, New Jersey, New York, North Carolina, Oregon, Rhode Island, Vermont, and Virginia.

Coalition’s letter. As observed by the coalition in its letter to the CFPB, the “disparate impact” theory of liability in the credit discrimination area declares that “practices, procedures, or tests neutral on their face, and even neutral in terms of intent, cannot be maintained if they operate to ‘freeze’ the status quo of prior discrimination.” The state AGs point out that they have “regularly relied on disparate impact theories in recent years to combat lending discrimination and ensure greater equality of opportunity.”

Moreover, the letter maintains that there are “no substantive grounds” for the CFPB to reconsider the federal government’s “more than 40 years of consistent interpretation that ECOA provides for disparate impact liability.” Referencing the U.S. Supreme Court’s 2015 ruling in Texas Department of Housing & Community Affairs v. Inclusive Communities Project, Inc., which found that the Fair Housing Act provided for disparate impact liability, the coalition notes that the operative wording of the applicable FHA provision is identical to the pertinent text of ECOA. According to the state AGs, the Court’s decision “dictates that the text of ECOA unambiguously provides for disparate impact liability.”

Statements by AGs. In their respective press releases pertaining to the coalition’s letter to Mulvaney, various state AGs offered statements as well. For instance, California Attorney General Xavier Becerra stressed that “[f]ighting systemic and structural inequality requires strong consumer protections.” According to Becerra, “[b]y weakening protections against credit discrimination, the Trump Administration threatens to undermine American equality and prosperity.” Similarly, New York Attorney General Barbara Underwood remarked that ECOA “was enacted because of our country’s sordid history of credit discrimination—and it’s unbelievable that the CFPB is considering refusing to use it to protect consumers.” Both Becerra and Underwood stated that they would continue combating credit discrimination and unfair lending practices through their respective state offices.

North Carolina Attorney General Josh Stein stated that, along with “the 13 other attorneys general in this coalition, I will continue to stand up for people so their lives aren’t damaged by credit discrimination. I urge the CFPB to fulfill its legal obligation to uphold nondiscriminatory lending practices.” Likewise, Rhode Island Attorney General Peter Kilmartin commented, “It is alarming that CFPB Director Mulvaney has indicated the agency is considering rolling back its responsibility to enforce nondiscriminatory lending requirements under the Equal Credit Opportunity Act, and this appears to be another effort to undermine the power and authority of the CFPB in protecting consumers.”

For more information about actions taken by state attorneys general affecting the financial services industry, subscribe to the Banking and Finance Law Daily.

CFPB denied enforcement of information demand on consumer data reporting website

By J. Preston Carter, J.D., LL.M.

The Consumer Financial Protection Bureau’s petition to enforce its civil investigative demand (CID) to a company was denied for failing to meet the statutory requirement that it advise the company of “the nature of the conduct constituting alleged violation which is under investigation and the provision of law applicable to such violation,” the U.S. Court of Appeals for the Fifth Circuit held (CFPB v. The Source for Public Data, LP, Sept. 6, 2018, Elrod, J.).

The CFPB issued a CID to the Source for Public Data, LP, a company that posts public record information about consumers on a website. Public Data objected to the CID for, among other things, failing to comply with the statute authorizing the CFPB to issue these demands (12 U.S.C. §5562). The CFPB filed a petition to enforce the CID, and the U.S. District Court for the Northern District of Texas granted the petition.

Whether the CID adequately described the nature of the conduct the Bureau was investigating, as required by 12 U.S.C. 5562(c)(2), was the main point of argument in the lower court. That court found the Bureau’s notification of purpose to be adequate. However, the appellate court disagreed. The judge said Section 5562(c)(2) requires that a civil investigative demand identify both: (1) “the nature of the conduct constituting the alleged violation which is under investigation;” and (2) “the provision of law applicable to such violation.” The judge found that the CFPB’s CID identified neither.

Nature of the conduct. The CID did not state the “conduct constituting the alleged violation which is under investigation,” the court said. The Bureau’s Notification of Purpose said it is investigating “unlawful acts and practices in connection with the provision or use of public records information.” However, judge said, this does not identify what conduct the CFPB believes constitutes an alleged violation. “Providing and using public records are not violations of federal law, and the CFPB fails to explain how these activities violate federal consumer law,” the judge said.

Applicable law. The judge also determined that, as the CID never identifies an alleged violation, it does not identify “the provision of law applicable to such violation.” Instead, the Notification of Purpose refers to the Fair Credit Reporting Act and states that the CFPB is investigating the violation of “any other federal consumer financial law.” In reaching its decision, the court referred to CFPB v. Accrediting Council for Independent Colleges & Schools, in which the U.S. District Court for the District of Columbia refused to enforce a CID the Bureau served on a college accrediting organization, as part of an investigation into student loan practices, because the Notification of Purpose was inadequate, failing to describe either the actions being investigated or the law that possibly was being violated. It did not provide a basis for a court to decide whether the bureau was acting under its statutory authority.

Reasonable relevance. The court added that it also could not enforce the Bureau’s administrative subpoena under the “reasonable relevance” standard. The CID failed to identify the conduct under investigation or the provision of law at issue.

Finally, using language from a 1994 D.C. District Court opinion, the judge said, “Simply put, the CFPB does not have ‘unfettered authority to cast about for potential wrongdoing.’”

For more information about CFPB enforcement actions, subscribe to the Banking and Finance Law Daily.

CFPB rule explains implementation of recent HMDA amendments

By Richard A. Roth, J.D.

The Consumer Financial Protection Bureau has adopted an interpretive and procedural rule to tell home mortgage lenders how it plans to implement Home Mortgage Disclosure Act amendments that were made by the Economic Growth, Regulatory Relief, and Consumer Protection Act. The Bureau also issued an executive summary of the new rule and a filing instruction guide for HMDA data collected in 2018.

 

The EGRRCPA included HMDA amendments that are intended to decrease the reporting burden on smaller depository institutions. To qualify for the less detailed itemization requirements, an institution must meet two tests.

 

Qualification criteria. First, the institution must have received acceptable Community Reinvestment Act ratings. An institution that was rated “substantial noncompliance” after its last CRA exam, or that was rated “needs to improve” after its last two exams, will not qualify for the relief offered by the EGRRCPA.

 

Second, the institution must not have reached a 500-loan threshold in either of the two previous years. Open-end and closed-end loans have separate thresholds. As a result, an institution that originated fewer than 500 closed-end loans in both of the two prior years, but more than 500 open-end loans in either or both of those years, could comply with the easier reporting requirements for the first category but not the second.

 

Lower reporting requirements. EGRRCPA exempts covered institutions from the 12 U.S.C. §2803(b)(5) requirement that they itemize the number and dollar amount of loans grouped by:

1. total points and fees;
2. the difference between the loan’s annual percentage rate and a benchmark; and
3. specified prepayment penalty information.

Covered institutions also are exempt from the 12 U.S.C. §2803(b)(6) requirement that they itemize the number and dollar amount of loans and applications grouped by:

1. the value of the collateral real estate;
2. the length of any introductory APR term;
3. the inclusion of contract terms that permit payments that are not fully amortizing;
4. the loan length;
5. the channel through which the application was received;
6. the loan originator’s unique identifier;
7. a universal loan identifier;
8. a parcel number that corresponds to the collateral property; and
9. loan applicants’ and mortgagors’ credit scores.

CFPB implementation explanation. According to the executive summary, the rule clarifies five issues about which some financial institutions have expressed confusion. As a starting point, it notes that Reg. C—Home Mortgage Disclosure (12 CFR Part 1003) specifies 48 data points that are to be collected and reported, but EGRRCPA gives qualifying institutions an exemption that covers 26 of them.

 

First, the rule makes clear that only loans defined in Reg. C as closed-end mortgage loans and open-end lines of credit count toward the 500-loan threshold. Loans that are excluded by Reg. C are not to be counted.

 

Second, in deciding whether an institution has met the CRA rating criterion, the ratings received before December 31 of the prior calendar years are the relevant ratings. 

 

Third, an institution that decides not to report a universal loan identifier must include a non-universal loan identifier that is adequate to make the loan identifiable.

 

Fourth, a financial institution may choose not to take advantage of the reduced compliance requirements. However, an institution that chooses to report an exempt data point must report all data fields the data point includes.

 

Fifth, the rule applies to data collected or to be reported on or after May 24, 2018. An institution that is eligible for the exemption does not need to collect exempt data after that date, and is not required to report in 2019 data that were collected earlier in 2018.

 

For more information about mortgage loan reporting requirements, subscribe to the Banking and Finance Law Daily.