The CFPB Mortgage Servicing Examination Procedures ... - K_L Gates

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					November 7, 2011
                     The CFPB Mortgage Servicing Examination
Practice Group:
                     Procedures Fail to Harmonize – Isn’t It
Mortgage Banking &
Consumer Financial
Products
                     Ironic?
                     By Jonathan D. Jaffe, Steven M. Kaplan, David I. Monteiro, and David A. Tallman
                     The Bureau of Consumer Financial Protection (the “Bureau” or the “CFPB”) was designed to provide
                     a single, integrated federal approach to consumer financial protection. But with the October 13, 2011,
                     release of its new Mortgage Servicing Examination Procedures (the “Procedures”), the CFPB appears
                     to leave it up to scores of individual examiners to decide in their subjective judgment whether a
                     company's loan servicing practices raise “unfair, deceptive, or abusive acts or practices” (“UDAAP”)
                     concerns. A federal government that is supposed to sing in one voice has not yet harmonized its
                     employees.
                     Even though these new Procedures remain a work in progress, the Bureau has indicated that it will
                     begin examining servicers in accordance with the Procedures in the fourth quarter of 2011—that is,
                     the quarter that started two weeks before the Procedures were released. In fairness, however, devising
                     an entirely new set of examination procedures is a substantial project for a new agency, and the
                     Bureau’s willingness to fully disclose so much of its guidance to examiners shows laudable
                     transparency. Further, although these Procedures offer servicers little comfort that the Bureau will
                     exercise its examination authority in a uniform or predictable manner, they at least provide a starting
                     point for servicers to begin conducting internal assessments.
                     In this Client Alert we address what the examination process might cover generally, and address
                     specific issues arising from the Procedures’ treatment of UDAAP, fair lending and the Fair Debt
                     Collection Practices Act (“FDCPA”) in a mortgage loan servicing setting. We will issue shortly
                     another Client Alert addressing the Consumer Risk Assessment process set forth in the Supervision
                     and Examination Manual (the “Manual”) and the Procedures, which is designed to assist the
                     examiners in evaluating supervised entities based on the amount of risk their activities pose to
                     consumers, identifying sources of risk, and assessing the quality of risk controls put in place by
                     supervised entities.

                     Background
                     The Procedures, which are effective immediately, were issued as part of Version 1.0 of the Manual.
                     The Manual is intended to describe how the Bureau will supervise and examine all consumer financial
                     service providers subject to its jurisdiction for compliance with the federal laws subject to its
                     examination authority1 (the “Consumer Laws”). However, the press release announcing the Manual
                     focused exclusively on the Procedures. This emphasis should come as little surprise, since the Bureau
                     has made clear in public comments and testimony that it intends to give particular scrutiny to
                     mortgage servicing practices. As Raj Date, Special Advisor to the Secretary of the Treasury for the
                     Bureau, succinctly stated in the press release issued in connection with the Procedures, “Mortgage
                     servicing has a huge impact on consumers and is a priority for the CFPB.”2
The CFPB Mortgage Servicing Examination Procedures
Fail to Harmonize – Isn’t It Ironic?

At this preliminary stage of the Bureau’s development, these Procedures apply only to servicers
affiliated with very large depository institutions—i.e., those with more than $10 billion in assets.3 The
Bureau does not have primary examination authority over smaller depository institutions, and it will
not be able to exercise its direct examination authority over non-depository financial services entities
until its Director is confirmed by the Senate.4 However, even servicers that are not affiliated with a
very large depository institution should pay heed to the Procedures, as such servicers might be subject
to CFPB examination under the Bank Service Company Act even before a Director is confirmed if
they service loans under contract for a very large bank or its affiliates.5 It remains to be seen the
extent to which the Bureau intends to exercise its examination authority over such non-depository
service providers during this interim period.

Procedure Modules
The Procedures are divided into nine “modules” that represent different aspects of mortgage
servicing—Transfers, Payment Processing, Customer Complaints, Escrows and Insurance, Credit
Reporting, Privacy, Collections, Loss Mitigation, and Foreclosures. Within each module, the
Procedures not only identify which substantive Consumer Laws apply to particular servicing
activities, but also set out what the CFPB euphemistically refers to as “Other Risks to Consumers.”
Although the Procedures are careful to use hedging language, this “Other Risks” category appears to
identify practices that the Bureau might consider actionable under its UDAAP authority. These
“Other Risks” are interesting in two respects. First, the Procedures appear to signal the Bureau’s
intent to apply its sweeping new “abusive” acts or practices authority broadly and aggressively.
Second, the Procedures offer some insight as to the types of compliance controls that the Bureau’s
examiners will look for.

Consumer Laws
The Procedures identify eight Consumer Laws that the Bureau has concluded apply to mortgage
servicing activities. Examiners are expected to assess a servicer’s compliance with each of these laws.
These statutes and their accompanying regulations will be familiar to servicers and should already be
an established part of their compliance programs. The laws include the Real Estate Settlement
Procedures Act6, the Truth in Lending Act7, the Electronic Funds Transfer Act8, the FDCPA,9 the
Homeowners Protection Act,10 the Fair Credit Reporting Act11, the privacy provisions of the Gramm-
Leach-Bliley Act,12 and the Equal Credit Opportunity Act,13 as well as the implementing regulations
of the preceding laws.
In many cases, the Bureau simply instructs examiners to assess whether the servicer is complying with
the laws, and gives a brief explanation of the law’s requirements or prohibitions, without providing
any substantive guidance or explanation. For example, the Procedures inform examiners in broad
terms of RESPA’s notice of transfer of servicing requirements, and Regulation Z’s notice of transfer
of ownership requirements, and then instruct the examiners to determine whether the servicer is
properly providing these notices to consumers. But the Bureau does not provide much in the way of
explanation. The Procedures also fail to address a number of Consumer Laws and other federal laws
applicable to servicers, or fail to tailor the discussion of those laws to mortgage servicing. In some
cases, this is because the CFPB does not have examination authority over certain laws that impact
servicers (e.g., the Servicemembers Civil Relief Act and the Telephone Consumer Protection Act).
But the Procedures omit provisions even under the Consumer Laws themselves. It is unclear whether
the CFPB does not address those portions of the Consumer Laws as a result of haste, or because it
does not intend to examine for those requirements. Further, while the narrative descriptions of the
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The CFPB Mortgage Servicing Examination Procedures
Fail to Harmonize – Isn’t It Ironic?

Consumer Laws in the Manual largely appear to be drawn from existing bank examination handbooks,
some narratives contain information that is out-of-date or incomplete, or fail to incorporate key
existing regulatory guidance, case law, or other interpretations. Perhaps these issues reflect the fact
that the Manual is—as the Bureau acknowledges—a work in progress that it will refine over time.
Regardless, the Bureau’s failure to address many of the complexities that arise when applying the
Consumer Laws to mortgage servicing activities will likely make it difficult for examiners who might
be unfamiliar with these laws’ nuances and ambiguities to apply them uniformly. In fairness to the
CFPB, the Manual and Procedures advise examiners that they should consult with “Headquarters” to
determine “whether a violation of a federal consumer financial law has occurred and whether further
supervisory or enforcement actions are appropriate.”

UDAAP
As noted earlier, Congress gave the Bureau authority to protect against “unfair, deceptive, or abusive
act[s] or practice[s]” in connection with consumer financial products and services. The “Other Risks
to Consumers” identified in the Procedures offer some insight into the potential application of the
Bureau’s UDAAP authority to mortgage servicing activities.14
While the concepts of “unfair” and “deceptive” practices have established meanings under Section 5
of the Federal Trade Commission Act (the “FTC Act”),15 the scope of the term “abusive” is largely
new and untested. The Procedures track the Dodd-Frank Act’s definition of “abusive” by providing
that an abusive act or practice is one that:
              1. Materially interferes with the ability of a consumer to understand a term
              or condition of a consumer financial product or service; or
              2. Takes unreasonable advantage of (i) a lack of understanding on the part
              of the consumer of the material risks, costs, or conditions of the product or
              service; (ii) the inability of the consumer to protect its interests in selecting
              or using a consumer financial product or service; or (iii) the reasonable
              reliance by the consumer on a covered person to act in the interests of the
              consumer.16
The Procedures imply that the Bureau might consider dozens of mortgage servicing practices to be
unfair, deceptive, or abusive, or at least suggestive of UDAAP violations. While some of the targeted
practices have an established legal basis in the “deception” standard under the FTC Act—such as the
practice of adding optional credit products to the loan without the consumer’s authorization—most
appear to be predicated on the more amorphous “unfair” or “abusive” standards.
The UDAAP-related portions of the Procedures contain two recurring areas of emphasis. First, the
Procedures consistently direct examiners to evaluate whether borrowers are well informed about their
accounts. Of course, almost by definition, this entails a subjective interpretation that the CFPB’s
examiners are likely to view through a normative lens—that is, viewed how the CFPB and its
examiners would like servicers to operate rather than how the law requires them to operate. The
Procedures also imply that virtually any action that a servicer takes that affects the amount due on the
loan or that could lead to foreclosure must be disclosed to the borrower in a timely, clear, accurate,
and understandable manner. Even though notices and disclosures relating to many of these actions are
already prescribed by state or federal law, the UDAAP provisions of the Procedures could be
interpreted by CFPB examiners—applying the UDAAP standard—to require even more extensive
notices and disclosures. The Procedures also focus heavily on records that the CFPB believes
servicers should create, maintain, and review throughout the life of the loan.
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The CFPB Mortgage Servicing Examination Procedures
Fail to Harmonize – Isn’t It Ironic?

The Bureau was careful to not expressly characterize any particular practices described as “Other
Risks” as unfair, deceptive, abusive, or otherwise unlawful. However, the Bureau clearly regards
them as suspect at best. Regardless of whether these practices should be prohibited as a matter of
public policy or safety and soundness, it is not clear that the newly established Bureau has the
expertise at this early phase to devise this kind of guidance. Further, it is unclear whether the Bureau
has the legal authority to limit or discourage some of these practices through the supervision process.
The three stated purposes of an examination under the Dodd-Frank Act are to (i) assess the examined
company’s compliance with the law, (ii) collect information about the company’s practices and
compliance systems, and (iii) detect new risks to consumers and markets.17 We believe the most
appropriate method for the Bureau to establish that a particular act or practice is unfair, deceptive, or
abusive is rulemaking under the Administrative Procedure Act. By doing so, all members of the
public may provide comment so the CFPB can consider all potential ramifications, and seek judicial
review when appropriate.
In addition, the vague and ambiguous framing of these standards is likely to cause problems for the
Bureau’s staff. Different examiners will undoubtedly have different views of how to apply these
“Other Risks” to particular servicers, creating the potential for inconsistent examination findings.
This risk is especially pronounced with respect to mortgage servicing, a complex area with which
some of the Bureau’s new corps of examiners are likely not familiar. Well-intentioned but
overzealous examiners might take the “Other Risks to Consumers” standards as license to impose
unrealistic demands on mortgage servicers, and the structure of the supervision process will afford
servicers little recourse. Of course, this always has been an issue with examiners from banking and
other federal agencies. The principal distinction here is that the CFPB is expecting its examiners to
interpret substantive UDAAP “law” that even courts have struggled with under existing federal and
state standards. The CFPB is also asking its examiners to interpret the new and untested concept of
“abusive” acts or practices, which is even more amorphous than the concepts of “unfair” and
“deceptive” acts or practices.

Policy Choices
The Procedures’ discussion of certain Consumer Laws raises additional issues that appear to arise
more from considered policy choices than lack of forethought. While this Alert does not discuss
every one of these substantive policy choices, we highlight below two particularly noteworthy issues.
The first involves fair lending, and the second, the FDCPA.

Fair Lending
The Procedures expressly direct examiners to look for fair lending violations in connection with
servicers’ loss mitigation efforts, foreclosure activity, and marketing of optional credit products.
Other federal regulators and enforcement authorities have also suggested in the past few years that
loss mitigation and foreclosures are an area of significant fair lending risk, so this focus should come
as no surprise. It is remarkable, however, how often the Procedures appear to frame the “Other Risks
to Consumers” and other substantive legal requirements as fair lending issues.
Most importantly, the Procedures incorporate disparate impact analysis into the examination process.
This is troubling for several reasons. First, it is not at all clear that disparate impact is a viable legal
theory under ECOA, even though other federal agencies, such as the Federal Trade Commission and
the Department of Justice, have brought suits in federal court asserting ECOA liability under a
disparate impact theory.18 Second, even to the extent a disparate impact analysis might apply, it is a

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The CFPB Mortgage Servicing Examination Procedures
Fail to Harmonize – Isn’t It Ironic?

nuanced theory that has been shaped by decades of Supreme Court precedent, and courts have not yet
devoted significant attention to how the theory might apply to mortgage servicing practices.

FDCPA
The Bureau’s summary of the FDCPA might signal that the CFPB intends to take an aggressive stance
with respect to the application of that statute to mortgage servicers. Most notably, the Procedures
contain a footnote that strongly suggests that the Bureau considers a debt to be “in default” when it is
just one day late, assuming that the contract so provides. The issue is significant because the FDCPA
does not cover a person who collects a debt that was not “in default” at the time that it was obtained
by that person.19 The legislative history of the FDCPA provides that this exemption is intended to
include “mortgage service companies and others who service outstanding debts for others, so long as
the debts were not in default when taken for servicing.”20 What constitutes a “default” for this
purpose is subject to varying interpretations among courts and other regulatory agencies and, in fact,
can vary depending on the terms of the promissory note, security instrument, and perhaps even
guidelines of government agencies such as the Department of Housing and Urban Development.
Unfortunately, the Bureau’s footnote adopts the most limiting definition. The CFPB’s apparent view
of when a debt is “in default” is more stringent than that taken by some other federal regulators. For
example, the Office of the Comptroller of the Currency (“OCC”) considers the following factors,
among others, when determining whether a debt is in default: (i) the creditor’s customary policies and
practices; (ii) the terms of the contract; (iii) determinations by the originator; and (iv) state law.21
Contrasting the OCC examination handbook to the Procedures, it is obvious the CFBP takes the more
expansive view of the scope of the FDCPA.

Planning for Examinations
What can servicers do in the face of this uncertainty? Despite the Procedures’ shortcomings, they do
offer at least one critical insight for servicers who are, or soon will be, subject to the Bureau’s
examination authority. The Procedures emphasize the need for formal internal controls and
compliance programs to a degree that servicers not used to being examined by banking regulators are
not accustomed. Indeed, the Bureau’s focus on a risk-based examination model illustrates how the
quality of a servicer’s existing controls could minimize the scope and intrusiveness of the
examination. A handful of examples of formal compliance systems that the Bureau’s examiners will
look for are:
         Systems to ensure the accuracy of disclosures;
         Formal systems for resolving and tracking consumer complaints;
         Procedures to ensure that borrowers are not improperly assessed force-placed casualty
          insurance;
         Policies to limit the risk of harassment in collections activity; and
         Processes that consistently and fairly determine when a loan is referred for foreclosure.
The more a servicer can show the Bureau that it maintains controls to mitigate compliance risks, the
more likely it is the Bureau will allocate its examination resources elsewhere. It is no coincidence that
the first stated objective of a mortgage servicer examination under the procedures is to “assess the
quality of the regulated entity’s compliance risk management systems, including internal controls and
policies and procedures, for preventing violations of federal consumer financial law in its mortgage

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The CFPB Mortgage Servicing Examination Procedures
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servicing business.” Among other things, the Bureau wants to know that servicers will police
themselves after examiners leave. This focus should be familiar to bank-affiliated servicers, but even
those servicers should reevaluate their existing internal controls to ensure that they correspond to the
Bureau’s assertive take on the Consumer Laws and UDAAP. Non-bank servicers (for which a federal
supervisory examination is a novel proposition) will probably have more time to prepare, but may
want to at least begin to review their practices and controls now.

Conclusion
Mortgage servicers face a powerful new regulator that will soon begin conducting examinations
through individual examiners who might not always sing from the same score. The Bureau seems to
be using its examination authority as a way to discourage practices that it views as potentially unfair,
deceptive, or abusive, without providing concrete guidance to examiners or examinees. If so, this
poses heightened risks to servicers, because supervision is not subject to the transparency or judicial
review inherent in the formal rulemaking process. Fortunately, the Procedures suggest that servicers
can mitigate some of this uncertainty by developing robust and effective systems of internal controls.
We appreciate the Bureau’s efforts to draft comprehensive Procedures for such a complex area of law
in such a short period of time, and we trust the sincerity of the Bureau’s commitment to consider and
incorporate feedback about the Procedures. Much of that feedback will certainly come in the course
of examinations, but it would have been preferable for that input to come through the Administrative
Procedure Act’s rulemaking process—particularly when the Bureau does not have a confirmed
Director. In any event, mortgage servicers might want to clarify and formalize existing policies and
procedures, consider their current practices in light of the Bureau’s UDAAP focus, and implement
strong controls with an eye to the mitigation of compliance risk.



Authors:
Jonathan D. Jaffe
jonathan.jaffe@klgates.com
+1. 415.249.1023


Steven M. Kaplan
steven.kaplan@klgates.com
+1. 202.778.9204


David I. Monteiro
david.monteiro@klgates.com
+1. 214.939.5462


David A. Tallman
david.tallman@klgates.com
+1. 202.778.9046




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The CFPB Mortgage Servicing Examination Procedures
Fail to Harmonize – Isn’t It Ironic?

1
 Those include the Alternative Mortgage Transaction Parity Act; the Consumer Leasing Act; the Electronic Fund Transfer
Act, with one exception; the Equal Credit Opportunity Act; the Fair Credit Billing Act; the Fair Credit Reporting Act, with
two exceptions; the Home Owners Protection Act; the Fair Debt Collection Practices Act; Subsections (b) through (f) of
Section 43 of the Federal Deposit Insurance Act; the privacy provisions of the Gramm-Leach-Bliley Act; the Home
Mortgage Disclosure Act; the Home Ownership and Equity Protection Act; the Real Estate Settlement Procedures Act; the
S.A.F.E. Mortgage Licensing Act; the Truth in Lending Act; and the Truth in Savings Act. The CFPB might also enforce
certain rules issued by the Federal Trade Commission and other agencies, including: the Telemarketing Sales Rule; the
Rule Concerning Cooling-Off Period for Sales Made at Homes or at Certain Other Locations; the Preservation of
Consumers’ Claims and Defenses Rule; the Credit Practices Rule; and the Mail or Telephone Order Merchandise Rule.

2
  Press Release, Consumer Financial Protection Bureau, Consumer Financial Protection Bureau Outlines Mortgage
Servicing Examination Strategy (Oct. 13, 2011), http://www.consumerfinance.gov/pressrelease/consumer-financial-
protection-bureau-outlines-mortgage-servicing-examination-strategy/.

3
 See Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”), Pub. L. No. 111-203, § 1025(a),
124 Stat. 1367, 1990 (2010).

4
    See id. § 1066(a), 124 Stat. at 2055.

5
  See 12 U.S.C. § 1867(c)(1) (“[W]henever a depository institution that is regularly examined by an appropriate Federal
banking agency, or any subsidiary or affiliate of such a depository institution that is subject to examination by that agency,
causes to be performed for itself, by contract or otherwise, any services authorized under this chapter . . . (1) such
performance shall be subject to regulation and examination by such agency to the same extent as if such services were
being performed by the depository institution itself . . . .”); see also Dodd-Frank Act, § 1025(d), 124 Stat. at 1991 (“A
service provider to a [very large bank] shall be subject to the [examination] authority of the Bureau under this section, to
the same extent as if the Bureau were an appropriate Federal banking agency under section 7(c) of the Bank Service
Company Act, 12 U.S.C. § 1867(c).”).

6
    12 U.S.C. §§ 2601 et seq.

7
    15 U.S.C. §§ 1601 et seq.

8
    Id. §§ 1693 et seq.

9
    Id. §§ 1692 et seq.

10
     12 U.S.C. §§ 4901 et seq.

11
     15 U.S.C. §§ 1681 et seq.

12
     Id. §§ 6801 et seq.

13
     Id. §§ 1691 et seq.

14
  While the Bureau might have the authority to examine financial institutions for UDAAP violations, it does not appear to
have the authority to enforce its UDAAP authority until a Director is confirmed and in place.

15
   An “unfair” act or practice is defined under the Dodd-Frank Act nearly the same as under the existing FTC Act standard
as one that “causes or is likely to cause substantial injury to consumers which is not reasonably avoidable by consumers;
and [as to which] such substantial injury is not outweighed by countervailing benefits to consumers or to competition.”
Dodd-Frank Act § 1031(c)(1), 124 Stat. at 2006; cf. 15 U.S.C. § 45(n) (providing that an “act or practice is unfair [if] the act
or practice causes or is likely to cause substantial injury to consumers which is not reasonably avoidable by consumers
themselves and not outweighed by countervailing benefits to consumers or to competition”); see generally FTC Policy
Statement on Unfairness, appended to Int’l Harvester Co., 104 F.T.C. 949, 1070 (1984) (devising and explaining the
standard later codified at § 45(n)). A “deceptive” act or practice is defined by established FTC policy as “a representation,
omission or practice that is likely to mislead the consumer acting reasonably in the circumstances, to the consumer’s
detriment.” See FTC Policy Statement on Deception, appended to Cliffdale Assocs., Inc., 103 F.T.C. 110, 174 (1984)
(devising this standard and explaining the source and rationale for each of its elements).



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16
     Cf. Dodd-Frank Act § 1031(d), 124 Stat. at 2006.

17
     Id. § 1025(a)(1)(A)–(C).

18
   See, e.g., Complaint ¶ 13, at 4, United States v. C&F Mortgage Corp., No. 3:11-cv-653 (E.D. Va. filed Sept. 30, 2011)
(“C&F Mortgage Corporation’s policy or practice of giving its employees wide subjective discretion in charging overages
and making available underages without requiring adequate documentation, monitoring, or training, had a disparate,
detrimental impact on black and Hispanic borrowers compared to similarly-situated white borrowers.”); see also K&L
Gates Client Alert – The FTC Pursues Its Own Seat at the Table of Fair Lending Enforcement (Oct. 5, 2010),
http://www.klgates.com/resources/xpqPublicationDetailKNLG.aspx?xpST=PubDetail&pub=6692.

19
   Specifically, the FDCPA excludes from the term “debt collector” any person “collecting or attempting to collect any debt
owed or due or asserted to be owed or due another to the extent such activity…concerns a debt which was not in default
at the time it was obtained” by that person. 15 U.S.C. § 1692a(6)(F)(iii) (emphasis added).

20
  See S. Rep. No. 382, 95th Cong., 1st Sess. 3, reprinted in 1977 U.S.C.C.A.N. 1695, 1698. See also Wadlington v.
Credit Acceptance Corp., 76 F.3d 103, 106–07 (6th Cir. 1996); Kvassy v. Hasty, 236 F. Supp. 2d 1240, 1270 (D. Kan.
2002); Hamilton v. Trover Solutions, Inc., No. 01-650, 2003 U.S. Dist. LEXIS 8296 (E.D. La. May 13, 2003); Franceschi v.
Mautner-Glick Corp., 22 F. Supp. 2d 250 (S.D.N.Y. 1998).

21
  OFFICE OF THE COMPTROLLER OF THE CURRENCY, COMPTROLLER’S HANDBOOK: OTHER CONSUMER PROTECTION LAWS AND
REGULATIONS,     at  31–32     (Aug.   2009),   http://www.occ.gov/publications/publications-by-type/comptrollers-
handbook/other.pdf.




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The CFPB Mortgage Servicing Examination Procedures
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K&L Gates’ Mortgage Banking & Consumer Financial Products practice provides a comprehensive
range of transactional, regulatory compliance, enforcement and litigation services to the lending and
settlement service industry. Our focus includes first- and subordinate-lien, open- and closed-end
residential mortgage loans, as well as multi-family and commercial mortgage loans. We also advise
clients on direct and indirect automobile, and manufactured housing finance relationships. In addition,
we handle unsecured consumer and commercial lending. In all areas, our practice includes traditional
and e-commerce applications of current law governing the fields of mortgage banking and consumer
finance.

For more information, please contact one of the professionals listed below.

LAWYERS
Boston
  R. Bruce Allensworth               bruce.allensworth@klgates.com     +1.617.261.3119
  Irene C. Freidel                   irene.freidel@klgates.com         +1.617.951.9154
  Stanley V. Ragalevsky              stan.ragalevsky@klgates.com       +1.617.951.9203
  Brian M. Forbes                    brian.forbes@klgates.com          +1.617.261.3152
  Andrew Glass                       andrew.glass@klgates.com          +1.617.261.3107
  Phoebe Winder                      phoebe.winder@klgates.com         +1.617.261.3196
Charlotte
  John H. Culver III                 john.culver@klgates.com           +1.704.331.7453
  Amy Pritchard Williams             amy.williams@klgates.com          +1.704.331.7429
Chicago
  Michael J. Hayes Sr.               michael.hayes@klgates.com         +1.312.807.4201
Dallas
  David Monteiro                     david.monteiro@klgates.com        +1.214.939.5462
Miami
  Paul F. Hancock                    paul.hancock@klgates.com          +1.305.539.3378
New York
  Philip M. Cedar                    phil.cedar@klgates.com            +1.212.536.4820
  Elwood F. Collins                  elwood.collins@klgates.com        +1.212.536.4005
  Steve H. Epstein                   steve.epstein@klgates.com         +1.212.536.4830
  Drew A. Malakoff                   drew.malakoff@klgates.com         +1.216.536.4034
San Francisco
  Jonathan Jaffe                     jonathan.jaffe@klgates.com        +1.415.249.1023
  Elena Grigera Babinecz             elena.babinecz@klgates.com        +1.415.882.8079
Seattle
  Holly K. Towle                     holly.towle@klgates.com           +1.206.370.8334
Washington, D.C.
  Costas A. Avrakotos                costas.avrakotos@klgates.com      +1.202.778.9075
  David L. Beam                      david.beam@klgates.com            +1.202.778.9026
  Melanie Hibbs Brody                melanie.brody@klgates.com         +1.202.778.9203
  Krista Cooley                      krista.cooley@klgates.com         +1.202.778.9257
  Daniel F. C. Crowley               dan.crowley@klgates.com           +1.202.778.9447
  Eric J. Edwardson                  eric.edwardson@klgates.com        +1.202.778.9387
  Steven M. Kaplan                   steven.kaplan@klgates.com         +1.202.778.9204
  Phillip John Kardis II             phillip.kardis@klgates.com        +1.202.778.9401
  Rebecca H. Laird                   rebecca.laird@klgates.com         +1.202.778.9038

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The CFPB Mortgage Servicing Examination Procedures
Fail to Harmonize – Isn’t It Ironic?


  Laurence E. Platt              larry.platt@klgates.com          +1.202.778.9034
  Phillip L. Schulman            phil.schulman@klgates.com        +1.202.778.9027
  Nanci L. Weissgold             nanci.weissgold@klgates.com      +1.202.778.9314
  Kris D. Kully                  kris.kully@klgates.com           +1.202.778.9301
  Morey E. Barnes                morey.barnes@klgates.com         +1.202.778.9215
  Kathryn M. Baugher             kathryn.baugher@klgates.com      +1.202.778.9435
  Emily J. Booth                 emily.booth@klgates.com          +1.202.778.9112
  Holly Spencer Bunting          holly.bunting@klgates.com        +1.202.778.9853
  Andrew L. Caplan               andrew.caplan@klgates.com        +1.202.778.9094
  Rebecca Lobenherz              becky.lobenherz@klgates.com      +1.202.778.9177
  Melissa S. Malpass             melissa.malpass@klgates.com      +1.202.778.9081
  David G. McDonough, Jr.        david.mcdonough@klgates.com      +1.202.778.9207
  Eric Mitzenmacher              eric.mitzenmacher@klgates.com    +1.202.778.9127
  Stephanie C. Robinson          stephanie.robinson@klgates.com   +1.202.778.9856
  Tori K. Shinohara              tori.shinohara@klgates.com       +1.202.778.9423
  Kerri M. Smith                 kerri.smith@klgates.com          +1.202.778.9445
  David Tallman                  david.tallman@klgates.com        +1.202.778.9046

PROFESSIONALS
Government Affairs Advisor / Director of Licensing
Washington, D.C.
  Stacey L. Riggin               stacey.riggin@klgates.com        +1.202.778.9202

Regulatory Compliance Analysts
Washington, D.C.
  Dameian L. Buncum              dameian.buncum@klgates.com       +1.202.778.9093
  Teresa Diaz                    teresa.diaz@klgates.com          +1.202.778.9852
  Robin L. Gieseke               robin.gieseke@klgates.com        +1.202.778.9481
  Brenda R. Kittrell             brenda.kittrell@klgates.com      +1.202.778.9049
  Dana L. Lopez                  dana.lopez@klgates.com           +1.202.778.9383
  Patricia E. Mesa               patty.mesa@klgates.com           +1.202.778.9199
  Daniel B. Pearson              daniel.pearson@klgates.com       +1.202.778.9881
  Jeffrey Prost                  jeffrey.prost@klgates.com        +1.202.778.9364




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