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AB 2424 Introduces New Borrower Foreclosure Protections and Notice Requirements
In September, Governor Newsom signed AB 2424, “Mortgages: foreclosure” (AB 2424), into law. AB 2424 establishes significant new foreclosure notice and sale requirements, which take effect on January 1, 2025. AB 2424 requires that a notice be provided to the borrower that a third party – such as a family member, HUD-certified housing counselor, or attorney – may record a request to receive copies of any notice of default and notice of sale at specified times in the loan and foreclosure process.
OCC Issues UDAP/UDAAP Handbook, Version 1.1
On December 3, 2024, the Office of the Comptroller of the Currency (OCC) issued Version 1.1 of the “Unfair or Deceptive Acts or Practices and Unfair, Deceptive, or Abusive Acts or Practices” section of the Comptroller’s Handbook (“UDAP/UDAAP Handbook”).
Senior Loan Officer Opinion Survey Reports Majority of Lending Standards Unchanged
On November 12, 2024, the October 2024 Federal Reserve’s Senior Loan Officer Opinion Survey on Banking Lending Practices (“SLOOS”) was released, addressing changes in standards and demand for bank loans to businesses and households over the third quarter of 2024.
CFPB Cites Navy Federal Credit Union for Overdraft-related UDAAPs
In early November, the CFPB announced that it had entered into a consent order with Navy Federal Credit Union (Navy Federal) following allegations that the credit union engaged in UDAAPs related to its overdraft fee practices. In addition to paying an $80 million restitution order as a result of its alleged UDAAPs, Navy Federal also agreed to pay a $15 million civil money penalty as part of the consent order.
Table of Contents
CONSUMER FINANCE
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AB 2424 Introduces New Borrower Foreclosure Protections and Notice Requirements
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New California Law Limits Use of Medical Debt in Credit Decisions
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FEMA Issues Final Rule on NFIP Installment Payments
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Fannie and Freddie Announce Further Fair Appraisal Updates to Selling Guides
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CFPB Issues More Regulation Z Annual Threshold Adjustments
BANKING OPERATIONS & FINTECH
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OCC Issues UDAP/UDAAP Handbook, Version 1.1
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CTA and Beneficial Ownership Rule Enjoined
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FDIC Issues Additional Q&As Regarding Official Signs and Advertising Requirements
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FinCEN Issues Advisory on Fraud Schemes Involving Generative AI and Deepfakes
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FDIC Delays Compliance Date on Final Rule for Official Signs and Advertising Requirements
COMMERCIAL LENDING
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Senior Loan Officer Opinion Survey Reports Majority of Lending Standards Unchanged
CREDIT UNIONS
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CFPB Cites Navy Federal Credit Union for Overdraft-related UDAAPs
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