Consumer Finance Litigation

On August 4, 2015 the Consumer Financial Protection Bureau (CFPB) issued a compliance bulletin on the private mortgage insurance (PMI) cancellation and termination provisions contained in the Homeowners Protection Act (HPA). The HPA applies to residential mortgage loans consummated on or after July 29, 1999. The Bulletin provides guidance from the CFPB on requirements in the HPA and lists specific examples of conduct the CFPB considers non-compliant. Prior to passage of the HPA, there were no federally imposed requirements on PMI. The HPA set an 80% loan to value threshold for ...