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A recent series of CFPB consent orders should remind the mortgage industry to carefully monitor its advertising practices. The MAP Rule prohibits deceptive and misleading commercial communications regarding any term of any mortgage credit product. 12 CFR Part 1014. The three orders, which were entered with reverse mortgage companies, include almost $800,000 in civil penalties and require remediation. Each of the consent orders will remain in place for five years. Each of the orders was entered with the consent, but without any admission of liability, by the reverse mortgage company.
Significantly for the mortgage industry, the consent orders provide insight into the CFPB’s expectations for compliance management as to advertising policies for mortgage products. The Orders require each respondent to develop a comprehensive compliance plan designed to ensure that each Respondent’s advertising complies with all applicable laws and regulations.
Mortgage industry players should carefully review their current policies and advertisements to ensure their compliance with the MAP Rule and are reminded to also shore up their vendor management in this regard, as well.
Caren Enloe is a partner who concentrates her practice in consumer financial services litigation and compliance, bankruptcy, and commercial litigation with an emphasis on creditor’s rights. She has a deep understanding of the complex compliance environment surrounding the financial services industry and regularly advises financial service companies on licensing and compliance issues involving state and federal consumer protection and finance statutes. Caren is the author of a daily blog titled: Consumer Financial Services Litigation and Compliance where she posts timely and informative updates regarding the CFPB, FTC, and a host of topical litigation issues involving consumer protection law....LEARN MORE