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Kearns To Fight Proposed Zombie Property Plans

Posted on October 4, 2019 by Safeguard

Industry Update
September 10, 2019

The City of Buffalo’s newly revised tax foreclosure process is drawing criticism from Erie County leaders who would no longer get their piece of the pie.

The plan is under fire from Erie County Clerk Mickey Kearns less than a month away now from the tax foreclosure auction.

Kearns, along with the Western New York Law Center, expressed concern to the city’s finance committee.

Under a newly revised policy, the city will keep all of the funds after a property is sold, instead of hanging on to what it’s owed and forwarding any surplus funds to the county.

Kearns says the city has already budgeted $4.8 million in revenue from the new procedure — funds Kearns says are vital to the former property owners who, under the former policy, were able to apply for some of those funds back to help get the back on their feet.

City leaders say people in good standing would be entitled to those profits but those opposed say there’s nothing in writing outlining that process.

“Unfortunately sometimes people lose their homes for many different reasons. That surplus funding is really important. Why kick people when they’re down? They’re going through a tough time, they could use those surplus funds to transfer into maybe a rental property,” Kearns (D) said.

“We believe the plan needs a lot more work and is not ready to be implemented next month. And we would ask for the council’s support in urging the city to hold off and hash these issues out a little more thoroughly,” said Amy Gathings, of the WNY Law Center.

Kearns says if the policy stands, the city would also take ownership of zombie properties in Buffalo as well, and would be charged with taking care of them.

City leaders don’t have a lot of time to rehash the issue, as the auction is set for October 8.

Legislation Addresses Crumbling Home Foundations in Connecticut

Posted on October 4, 2019October 4, 2019 by Safeguard

Legislation Update
October 1, 2019

Source: Connecticut General Assembly

Additional Resource:

Patch (Oct. 1 Means New Laws, Taxes In CT: Here’s The Full List)

PA 19-192–sHB 7179
AN ACT CONCERNING CRUMBLING CONCRETE FOUNDATIONS.

To (1) require the Commissioner of Housing to establish a grant program to support the development of methods and technologies that reduce the average cost of repairing and replacing concrete foundations in this state that have deteriorated due to the presence of pyrrhotite, (2) establish an innovation board to review applications for grants filed as part of such program, (3) appropriate the sum of eight million dollars to fund grants awarded as part of such program, (4) modify the Healthy Homes Fund surcharge, and (5) redefine the term “residential building” as such term applies to various statutes concerning crumbling concrete foundations.

Similar Enacted Bills: Session Year 2019

sHB 7286
AN ACT CONCERNING HOME INSPECTORS AND APPRAISERS.

To allow certified home inspectors to inspect certain building foundations and to require appraisal management companies to compensate appraisers fairly.

Signed by Governor: 7/9/19
Effective Date: 10/1/19

Similar Proposed Bills: Session Year 2019

HB 5163
AN ACT CONCERNING DEFICIENCY JUDGMENTS AND RESIDENTIAL PROPERTIES WITH A CONCRETE FOUNDATION AFFECTED BY PYRRHOTITE.

To (1) prohibit deficiency judgments on mortgage loans where the property secured by the mortgage has a crumbling concrete foundation, (2) prohibit mortgage lenders and mortgage correspondent lenders from denying an application for a residential mortgage loan based solely on certain prior defaults, conveyances or foreclosures by the applicant, and (3) prohibit mortgage lenders and mortgage correspondent lenders from reporting to credit rating agencies that mortgage loans secured by property with a crumbling concrete foundation are subject to a deficiency judgment.

HB 5164
AN ACT PROHIBITING THE LENDER OF A HOME EQUITY LOAN FROM SEEKING A DEFICIENCY JUDGMENT AGAINST CERTAIN BORROWERS.

To protect homeowners with crumbling foundations from a deficiency judgment on a home equity loan.

HB 5432
AN ACT CONCERNING THE FORECLOSURE MEDIATION PROGRAM.

To protect a homeowner who is subject to foreclosure as the result of owning a home with a crumbling foundation.

HB 5890
AN ACT CONCERNING THE REASSESSED VALUE OF A RESIDENTIAL BUILDING WITH A FOUNDATION MADE WITH DEFECTIVE CONCRETE.

To allow an owner to request and require a municipality to apply retroactively the reassessed value of a residential building with a foundation made with defective concrete to the date such owner purchased or received such building.

HB 5969
AN ACT ESTABLISHING A COLLAPSING FOUNDATIONS LOAN PROGRAM TO PROVIDE LOW-INTEREST LOANS TO CERTAIN PROPERTY OWNERS.

To provide low-interest loans to property owners who (1) have received the maximum amount of financial assistance provided by the captive insurance company for the purpose of repairing or replacing a concrete foundation that has deteriorated due to the presence of pyrrhotite, and (2) require additional funding for such repair or replacement.

HB 6040
AN ACT REQUIRING THE INSPECTION OF CERTAIN RESIDENTIAL BUILDINGS BY A HOME INSPECTOR AND AN ENGINEER PRIOR TO THE TRANSFER OF TITLE.

To require owners of certain residential buildings to retain a home inspector and an engineer to prepare inspection reports concerning such buildings prior to transferring title to such buildings.

HB 6557
AN ACT CONCERNING THE REASSESSMENT OF RESIDENTIAL BUILDINGS MADE WITH DEFECTIVE CONCRETE.

To increase the number of assessment years for which a reassessment of the value of a residential building made with defective concrete shall be applicable.

HB 6659
AN ACT REQUIRING SELLERS OF RESIDENTIAL PROPERTY TO DISCLOSE THE PRESENCE OF PYRRHOTITE IN RESIDENTIAL CONDITION REPORTS.

To require persons selling residential property in this state to disclose the presence of pyrrhotite.

HB 6750
AN ACT EXPANDING THE DEFINITION OF “RESIDENTIAL BUILDING” IN STATUTES PROVIDING ASSISTANCE TO CERTAIN HOMEOWNERS.

To revise the definition of “residential building” to include any condominium unit or dwelling in a planned unit development.

SB 907
AN ACT CONCERNING THE RESIDENTIAL DISCLOSURE REPORT AND CRUMBLING CONCRETE FOUNDATIONS.

To require a seller to disclose to a purchaser in the “Residential Condition Report” any facts that are within the seller’s actual knowledge concerning (1) the presence of pyrrhotite in the concrete foundations located on the seller’s property, (2) any testing or inspection done by a licensed professional to determine whether such foundations contain pyrrhotite, (3) any foundation deterioration, problems or settling caused by the presence of pyrrhotite in such foundations, and (4) any repairs to remedy such deterioration, problems or settling.

Managing a Counter-Cyclical Business

Posted on October 2, 2019October 2, 2019 by Safeguard

Editorial
September 30, 2019

Source: DS News (Managing a Counter-Cyclical Business PDF)

In 2011, during the height of the U.S. recession and housing crisis, the Washington Post published an article about the mortgage field services industry with the headline, “Good business for bad times: Mortgage field services.” Featuring Safeguard Properties, the article explained that when the economy is faltering and foreclosures increase, these types of companies tend to flourish.

It is the nature of the business. When the U.S. housing crisis hit in 2008, national field services companies such as Safeguard experienced a huge influx of work from their mortgage servicing clients as the volume of foreclosures elevated.

But it works both ways. In good economic times, mortgage field services companies can see declining revenue as foreclosure and vacant housing volumes decrease significantly. These periods serve as the best time to evaluate processes, be innovative, and make improvements that benefit default servicing clients.

Over the past few years, Safeguard has remained the industry leader by developing best practices and investing in innovative technology. We have taken a closer look at our business practices and identified the top five areas of default management that mortgage field services companies should evaluate when the economy is at its peak.

Streamlining Vendor Management—In any field services industry, your boots-on-the-ground network is the backbone of the business. Thousands of inspectors and contractors work diligently every day to ensure orders are completed properly and timely, and that vacant properties are protected and secured. When foreclosure volumes are high, they rely on well-tested processes established by their mortgage field services provider to ensure the highest level of quality assessment and results.

When the economy is healthy and volumes have leveled off, a comprehensive review of workflow and business processes can help identify areas needing improvement. This is beneficial to not only the property preservation company, but also to the vendor network and mortgage servicing clients. By seeking vendor suggestions and feedback, Safeguard was able to tweak its processes to streamline the vendor’s workflow, making it easier to complete work and reduce errors. This review also helped to improve timeliness without compromising quality of our services for our clients.

Perfecting the Bidding Process—Getting bids approved to mitigate damages or other issues at a vacant or abandoned property outside of allowables in any stage of the foreclosure process can be a challenge for a property preservation vendor. Guidelines and work order-level rules that differ by mortgage servicer or investor can potentially lead to missed protocols or information. Taking time to work with investors to define best practices on avoiding denials due to missing or inaccurate information is key to getting bids approved. This gives the mortgage field services company an opportunity to set expectations and adjust internal systems to require specific information when vendors are in the field and identify damages.

Tackling the Federal Housing Administration (FHA) Process—Reconveyances are one of the biggest challenges mortgage servicers face. Coupled with changes in leadership, guidelines, HUD vendors, and the interpretations of regulations, property preservation companies and their mortgage servicing clients face some significant hurdles with completing work at properties with FHA loans. Examining new ideas that will help avoid reconveyances and exploring ways to improve the FHA post-sale process allow work to be completed timely and accurately. Utilize this period of decreased volumes to add controls and increased visibility for your mortgage servicing clients around the FHA process. This allows them to have full case management around any property issues and access to real-time reporting.

Implementing New Technology—Technology changes so rapidly and often when foreclosure volumes are at their peak, it can be difficult to make significant upgrades. However, updating and testing new technology is an important endeavor. Safeguard has implemented video and panoramic photo capabilities to our mobile platforms in recent years. We also enhanced our workflow through the new SafeView Field Services platform, including developing continuous improvements to our client integrated system to allow for greater understanding of a property/loan at a glance.

Updating Disaster Protocols—While natural disasters pose a problem for mortgage servicers’ portfolios in the affected areas, the industry has made great strides to implement plans to prepare properties in the line of a storm and manage damages once it subsides. For mortgage field services providers, ensuring their vendor networks in surrounding areas are equipped to handle the influx of work is key. This includes taking on orders for occupied properties with current loans. A critical area to review is your insurance loss inspection process. Having the ability to consistently re-evaluate this practice can be beneficial in both mitigating damages and ensuring the affected properties are being repaired properly.

While some officials suggest the U.S. may be heading for another recession, it remains clear that mortgage field services companies need to remain proactive and utilize the good economy to re-evaluate systems and processes. Take this opportunity to be innovative and make improvements to benefit your vendor networks and default servicing clients.

Tim Rath is the AVP of business development for Safeguard Properties, the mortgage field services leader. Many of these tips for improvements in good times are discussed during the annual National Property Preservation Conference. This year’s event takes place from Nov. 3-5 at The Mayflower Hotel in Washington, D.C. For more information or to register, visit NPPConf.com.

FEMA Declared Disaster South Carolina

Posted on October 1, 2019October 1, 2019 by Safeguard

FEMA Alert
September 30, 2019

FEMA issued a Presidential Major Disaster Declaration for areas in South Carolina affected by Hurricane Dorian from August 31 to September 6, 2019.

The following counties are eligible for assistance:

Public Assistance

Beaufort
Berkeley
Charleston
Colleton
Dillon
Dorchester
Georgetown
Horry
Jasper
Marion
Williamsburg

South Carolina Hurricane Dorian (DR-4464)

FEMA Declared Disaster South Carolina: ZIP Code List

Additional Resources

FEMA’s web site

FEMA’s Disaster Declaration Process

Safeguard Properties Industry Alerts

HUD Moratorium on Foreclosure

VA’s Policy Regarding Natural Disasters

Freddie Mac Disaster Relief Policies

Fannie Mae’s Natural Disaster Relief Policies

Examining the Single-Family Rental Market

Posted on September 26, 2019 by Safeguard

Safeguard in the News
September 23, 2019

Source: DS News

On Monday, the Five Star Conference began with the third Single-Family Rental (SFR) & Investment Roundtable, a hyper-focused event that allowed attendees to learn more about the available opportunities that can help SFR investors meet their objectives. Attendees also heard valuable insights from industry experts on how they could continue to meet their performance objectives by partnering with the right investors and lenders.

The day-long event saw expert panels give insights into rehab, acquisition, funding, market overview, due diligence, and technology innovations in SFR.

Opening the proceedings, Jeffrey Tesch, CEO, RCN Capital and the Event Director for the Roundtable, said that the U.S. currently has the highest rate of investment since 1999; 11% of all investment properties are bought by single-family investors.

“This is truly monumental. It’s amazing how far we’ve come in a short time,” Tesch said.

The first session—titled, “Latest and Greatest: Cutting-Edge Lending Strategies for SFR & Investment Markets,” and moderated by Tesch—focused on the options and instruments available for investors to improve their return on investment (ROI). The session featured Glen Mather, CEO, NuView IRA; Alex Offutt, Managing Director, Constructive Loans; Chase Scott, Head of Servicing and Asset Management, LendingHome; and Dennis Spivey, VP, CoreVest Finance, all of whom gave insights into new lending products and financing strategies that could be the best fit for an SFR investor.

“Single-family rental has transformed over the past few years moving from large corporations to small investors with a minimal number of properties,” Spivey said, explaining how this market has now become available to every investor.

“A lot of it in this particular space is more of a knowledge share, so if you could create what we mentioned [during the panel] was a membership profile so you don’t have to underwrite, it allows [the borrowing process] to be more seamless on the upfront,” Scott suggested.

During the session on asset rehab strategies, moderated by Rebecca McLean, Executive Director of National REIA and featuring John Gordon, Director National Accounts, Home Depot Pro; Kevin Jonas, SVP, Bayview Loan Servicing; and Bill McGee, VP Sales & Strategic Partnerships, Alacrity Services, the panel discussed why smart rehab was key to effective SFR investments and the best, cost-effective strategies to increase the value of a property.

Martin Kay, Founder & CEO, Entera, turned the spotlight on the evolution of residential real estate and how technology like big data was changing the future of homebuying.

The next session dived deep into due diligence and its importance in SFR investments. Moderated by Lori Eshoo, President & CEO, National Tax Search, the panel consisting of Rob Dewald, Co-Founder & CEO, Precedent Management; Lee Rogers, President, realprotect; and Brandon Winters, CEO, eMerge Property Solutions. Together, they gave insights into the factors that can affect the value of a transaction, as well as the potential impact of HOAs, insurance, property tax, and valuation.

In “Bringing in Help,” moderator Charles Tassell, COO, NREIA, along with his fellow panelists Aaron DiCaprio, CEO, Rent Rescue; Scott Heimel, VP, Property Frameworks; and Tucker McDermott, VP of Sales, Real Estate, SMS Assist, then delved into the factors and trends that SFR investors must consider before they bring in outside property managers.

“If you want to scale as an entrepreneur, you better have third-party management. That’s first and foremost,” Tassell said during the event. “After that are some very specific questions to ask.” The panel covered factors such as cost, background, and certifications.

“When it comes to third-party management, know what you actually need,” he added.

Stuart DenyerIn an afternoon keynote, Stuart Denyer, CEO, Sherman Bridge Lending, took the audience through the fundamentals of the housing market and how they can impact an investor’s bottom line. He also focused on the trends that were likely to impact the SFR market in particular and the steps that investors should take to adapt to changing market conditions.

“Everyone in this section of the industry needs to stay aware of changing horizons,” Denyer said. “The whole market is changing. The way business is done and handled is all moving quickly, and it’s important to stay as up-to-date as possible.”

Next, a session on tech innovations was moderated by Zach Bassett, VP, Field Operations, Property Masters, and featured Inaas Arabi, VP of Single-Family, General Manager, Propertyware; Jeff Cline, Executive Director – Principal, SVN; and Tim Rath, AVP, Business Development & Marketing, Safeguard Properties. The panel discussed the technology that is available for entry-level investors and how it can support the growth of their portfolio.

Zach Bassett’s biggest takeaway from the panel was the availability of ways to increase productivity.

“Obviously the technology is helping with everyone’s productivity, but at the end of the day we still need humans,” Bassett said. “It’s great because we can keep our jobs, but we couldn’t be near as successful with paper maps and landlines.”

The day ended with a panel discussion on how investors can adapt to a changing environment. The session was moderated by Johnny Pannell, Senior Advisor, Enterprise Sales Manager, 5arch and featured and Lou Brown, CEO, Certified Affordable Housing Provider; Chris Clothier, Partner & VP of Sales & Marketing, Memphis Invest; Bryan McLain, Founder & CEO, McLain Companies; and Josh McLeod, VP, American Homes 4 Rent.

Star Sponsorship for the Single-Family Rental and Investment Roundtable was provided by CoreVest Finance, Home Depot Renovation Services, and RCN Capital. Corporate Sponsoship for the event was provided by Ark Forecast, Certified Affordable Housing Provider, Constructive, eMerge Property Solutions, Globus, Memphis Invest, Property Frameworks, Property Masters, and Rent Rescue.

HUD: FHA INFO #19-48: HECM Policy Updates

Posted on September 26, 2019 by Safeguard

Investor Update
September 23, 2019

Source: HUD

The Federal Housing Administration today published multiple policy updates to its Home Equity Conversion Mortgage (HECM) program. Today’s updates include the HECM Mortgagee Optional Election (MOE) Assignment Options for non-borrowing spouses and the continuation of the HECM collateral risk assignment requirements. See below for details.

FHA Issues Updated Guidance on Home Equity Conversion Mortgage (HECM) Mortgagee Optional Election Assignment Options

Today, under the Reverse Mortgage Stabilization Act (RMSA) authority, the Federal Housing Administration (FHA) issued Mortgagee Letter (ML) 2019-15, Updates to Mortgagee Optional Election (MOE) Assignment for Home Equity Conversion Mortgages (HECMs) with FHA case numbers assigned prior to August 4, 2014. This ML — in addition to providing updated guidance — eliminates all interim deadlines for MOE Assignments that were outlined in ML 2015-15 for HECM case numbers issued prior to August 4, 2014.

Since implementation of the MOE Assignment process outlined in ML 2015-15, FHA has found that several of its requirements obstructed mortgagees’ election of the assignment option. To address these issues, and to improve the fiscal safety and soundness of the HECM program, FHA is modifying the requirements for HECM MOE Assignment claims by:

• Eliminating the interim MOE Assignment election and assessment deadlines, along with associated notification requirements;
• Eliminating the 120-day timeframe for bringing current all property charges on a HECM loan that is subject to a pre-existing loss mitigation repayment plan;
• Establishing a 180-day reasonable diligence timeframe to initiate an MOE Assignment;
• Eliminating the requirement for an eligible surviving non-borrowing spouse to obtain good and marketable title to the property that secured the HECM or demonstrate the legal right to reside in the property for life, and modification of related certifications and assignment criteria;
• Updating the definition of eligible non-borrowing spouse; and
• Requiring mortgagees to request information from borrowers to attempt to identify non-borrowing spouses.

To view full update, please click the source link above.

VA: VALERI Special Announcement

Posted on September 26, 2019September 26, 2019 by Safeguard

Investor Update
September 26, 2019

Source: VA

The VALERI application will be unavailable on Friday, September 27, 2019, from 9:00 PM EST until Sunday, September 29, 2019, 11:59 PM EST for a system deployment. Please refrain from using the application during this time.

The deployment will include the following items:

• Launches the Review Post Audit Claim, Incentive, and Partial Release of Security process. The Post Audit Selection and Status report will be available on October 1, 2019. A list of required documents by post audit type is linked here and available in VALERI under Knowledge.

• Enables servicers to submit pre-approval requests in the Servicer Web Portal (SWP). Submission of the request notifies the assigned technician on the loan to review the pre-approval request. The Pre-Approval Status Report will be available after October 31, 2019.

• Enables servicers to appeal a Post Audit decision in SWP, via the Review Appealed Post-Audit Claim or Incentive process.

• Corrects a gap in the Supplemental Claim logic to include additional days of interest granted on previous Appeal Claims to be copied into the Supplemental Claim.

• Resolves an issue with monthly Delinquency Status Update (DSU) event generation that would miss a month under certain date conditions.

• Updates the logic in the Default Resolution Rate (DRR) Report to exclude rejected, withdrawn, and cancelled events.

If there are any questions, please feel free to contact the VALERI Help Desk at VALERIHELPDESK.VBACO@va.gov.

Thank you for your cooperation.

VALERI Helpdesk
VA Central Office Loan Management

FHFA: New Strategic Plan and Scorecard for Fannie Mae and Freddie Mac

Posted on September 26, 2019November 1, 2019 by Safeguard

Investor Update
October 28, 2019

Source: FHFA

Washington, D.C. – The Federal Housing Finance Agency (FHFA) today released a new Strategic Plan for the Conservatorships of Fannie Mae and Freddie Mac and a new 2020 Scorecard for Fannie Mae, Freddie Mac, and Common Securitization Solutions. The Strategic Plan provides a framework for how FHFA will guide Fannie Mae and Freddie Mac (the Enterprises) to fulfill their statutory missions, focus on safety and soundness, and prepare for a responsible end to the conservatorships. The Scorecard aligns the Strategic Plan with the Enterprises’ tactical priorities and operations, serving as an essential tool to hold the Enterprises accountable for the effective implementation of the Strategic Plan.

“Our nation’s mortgage finance system is in urgent need of reform,” said FHFA Director Mark Calabria. “The vision for reform articulated in the Strategic Plan and advanced in the Scorecard will serve borrowers and renters by preserving mortgage credit availability, protect taxpayers by ensuring Fannie Mae and Freddie Mac can withstand an economic downturn, and support a strong and resilient secondary mortgage market.”

The three objectives of this new Strategic Plan and Scorecard are to ensure that the Enterprises:

1. Focus on their core mission responsibilities to foster competitive, liquid, efficient, and resilient (CLEAR) national housing finance markets that support sustainable homeownership and affordable rental housing;

2. Operate in a safe and sound manner appropriate for entities in conservatorship; and

3. Prepare for their eventual exits from the conservatorships.

Links to: 2019 Strategic Plan for the Conservatorships of Fannie Mae and Freddie Mac and 2020 Scorecard for Fannie, Mae, Freddie Mac, and Common Securitization Solutions

CFPB: Policies to Facilitate Compliance and Promote Innovation Issued

Posted on September 26, 2019September 26, 2019 by Safeguard

Industry Update
September 10, 2019

Source: CFPB

First No-Action Letter Issued to HUD Housing Counseling Agencies

WASHINGTON, D.C. – The Consumer Financial Protection Bureau (Bureau) today issued three new policies to promote innovation and facilitate compliance: the No-Action Letter (NAL) Policy, Trial Disclosure Program (TDP) Policy, and Compliance Assistance Sandbox (CAS) Policy. The Bureau proposed the policies in 2018 and received public comments on each from a diverse array of stakeholders.

Regulatory uncertainty can hinder the development of innovative products and services that benefit consumers. NALs provide increased regulatory certainty through a statement that the Bureau will not bring a supervisory or enforcement action against a company for providing a product or service under certain facts and circumstances. The new NAL Policy improves on the Bureau’s 2016 NAL Policy by having, among other things, a more streamlined review process focusing on the consumer benefits and risks of the product or service in question.

The Bureau today issued its first NAL under the new NAL Policy in response to a request by the Department of Housing and Urban Development (HUD) on behalf of more than 1,600 housing counseling agencies (HCAs) that participate in HUD’s housing counseling program. In 2018, HUD brought concerns to the Bureau about HCAs and lenders not entering into agreements that would fund counseling services due to uncertainty about the application of the Real Estate Settlement Procedures Act (RESPA). Expressing similar concerns, the Coalition of HUD Intermediaries filed a comment letter in February 2019 noting the insufficiency of the Bureau’s old NAL Policy and supporting the new NAL proposed policy. The no-action letter essentially states that the Bureau will not take supervisory or enforcement action under RESPA against HUD-certified HCAs that have entered into certain fee-for-service arrangements with lenders for pre-purchase housing counseling services. The NAL, which is an exercise of the Bureau’s supervisory and enforcement discretion, is intended to facilitate HCAs entering into such agreements with lenders and will enhance the ability of housing counseling agencies to obtain funding from additional sources.

Under the new TDP Policy, entities seeking to improve consumer disclosures may conduct in-market testing of alternative disclosures for a limited time upon permission by the Bureau. The Dodd-Frank Act gives the Bureau the authority to provide certain legal protections for entities to conduct trial disclosure programs, as outlined in the TDP Policy. The new policy streamlines the application and review process.

The CAS Policy enables testing of a financial product or service where there is regulatory uncertainty. After the Bureau evaluates the product or service for compliance with relevant law, an approved applicant that complies in good faith with the terms of the approval will have a “safe harbor” from liability for specified conduct during the testing period. Approvals under the CAS Policy will provide protection from liability under the Truth in Lending Act, the Electronic Fund Transfer Act, or the Equal Credit Opportunity Act.

“Innovation drives competition, which can lower prices and offer consumers more and better products and services. New products and services can expand financial options, especially to unbanked and underbanked households, giving more consumers access to the benefits of the financial system. The three policies we are announcing today are common-sense policies that will foster innovation that ultimately benefits consumers.” said Consumer Financial Protection Bureau Director Kathleen L. Kraninger.

The NAL policy can be found here: https://files.consumerfinance.gov/f/documents/cfpb_final-policy-on-no-action-letters.pdf

The CAS policy can be found here: https://files.consumerfinance.gov/f/documents/cfpb_final-policy-on-cas.pdf

The TDP policy can be found here: https://files.consumerfinance.gov/f/documents/cfpb_final-policy-to-encourage-tdp.pdf

The HUD NAL may be found here: https://files.consumerfinance.gov/f/documents/cfpb_HUD-no-action-letter.pdf

The associated HUD NAL template may be found here: https://files.consumerfinance.gov/f/documents/cfpb_HUD-no-action-letter-template.pdf

The associated HUD NAL application may be found here: https://files.consumerfinance.gov/f/documents/cfpb_HUD-no-action-letter-application.pd

CFPB: Executive Team Additions Announced

Posted on September 26, 2019 by Safeguard

Industry Update
September 25, 2019

Source: CFPB

WASHINGTON, D.C. — The Consumer Financial Protection Bureau (Bureau) today announced the following additions to its executive team:

Desmond Brown will serve as the Deputy Associate Director for the Consumer Education and Engagement Division. Mr. Brown has more than two decades of experience working with national and local organizations to increase financial well-being and economic opportunities for consumers. He first joined the Bureau as a program specialist for the Office of Financial Empowerment in 2012. He earned his Masters of Policy Management from Georgetown University, and his B.S. in Political Science from Southern Connecticut State University.

Jason Brown will serve as Assistant Director for Research. Mr. Brown has 16 years of Federal service, most recently as Associate Commissioner in Office of Research, Evaluation, and Statistics at the Social Security Administration. Prior to this appointment he served in numerous capacities as an economist at the Department of the Treasury. Mr. Brown earned his B.A. in Economics from Texas A&M University and Ph.D. in Economics from Stanford University.

Karla Carnemark will serve as the Deputy Chief of Staff. Ms. Carnemark joins the Bureau with more than 20 years of experience in public service, project management and government affairs. She has worked with senior-level government executives from the U.S. Department of Defense, U.S. Department of Commerce and the U.S. Department of Transportation. Ms. Carnemark also served on Capitol Hill on the staff of Rep. Deborah Pryce (OH). Ms. Carnemark received her B.A. from Lynchburg College.

Ren Essene will serve as Chief Data Officer. Ms. Essene has served at the Bureau in a number of capacities since 2011. She previously worked at the Federal Reserve, and her career in information management and housing issues spans over 25 years. Ms. Essene earned her B.S. in Architecture from the University of Illinois at Urbana-Champaign and M.P.A. from the Kennedy School of Government at Harvard University.

Bryan A. Schneider will serve as Associate Director in the Supervision, Enforcement and Fair Lending Division. Mr. Schneider most recently served as the Secretary of the Illinois Department of Financial and Professional Regulation, a cabinet-level agency. He worked for the Walgreen Co. for 15 years in numerous capacities, from divisional vice president and assistant general counsel to senior attorney. Mr. Schneider earned his B.S. in Accounting from Trine University, his M.B.A. from DePaul University and J.D. from the University of Wisconsin Law School.