dodd-frank wall street reform and consumer protection act

New CMBS Model Should Focus on Ownership – add a Stick to the Carrot

March 13, 2012 12:43

Much of the discussion surrounding “cures” to the CMBS model focuses on using “risk retention” as a consequence to the loan originator, which forces the commercial lender to bear the loss.  That hurts.  It’s a real stick. The model needs a carrot and a stick.  ...

Proposed Identity Theft Red Flags Rules

Doug Cornelius
February 29, 2012 13:00

Identity theft is a serious problem. Title X of the Dodd-Frank Wall Street Reform and Consumer Protection Act increased the scope of firms that would be subject to federal regulatory requirements on identity theft rules. The Securities Exchange Commission and the Commodities Futures Trading...

Dodd-Frank Does Not Preempt All California's § 1011(c) Reinsurance Approval Requirements Applicable to Foreign Insurers

February 14, 2012 17:05

By Michael Rosenfield and Chris Burusco Prior to the Dodd-Frank Act, California Insurance Code § 1011(c) required all California-admitted insurers to obtain prior approval from the California Department of Insurance for any reinsurance transaction that exceeded a 50% or 75% threshold....

CFPB Publishes Rules for Nonbank Mortgage Lenders

Fred Rivera
January 12, 2012 17:15

On January 11, 2012, the Consumer Financial Protection Bureau (CFPB) released new procedures for regulating nonbank mortgage lenders.  The Mortgage Origination Examination Procedures apply to independent lenders, brokers, servicers, and others unaffiliated with banks and depository...

The SEC and Rating Agencies

Doug Cornelius
October 11, 2011 12:00

The SEC examined all 10 firms registered Nationally Recognized Statistical Rating Organization (.pdf 23 pages) and found all 10 had “apparent failures”. The SEC has requested remediation plans from each of the agencies within 30 days and is continuing its investigation. The issues found...