Does the Consumer Financial Protection Bureau (“CFPB”) have jurisdiction over “commercial credit”? Rep. Emanuel Cleaver II, raised certain concerns in a recent letter to the CFPB (the “Cleaver Letter”) , which can help us answer this question. As we know, fintech lending is based upon the use of algorithms to determine whether to provide commercial […]
Continue reading →My firm specializes in transactions, regulations, strategic alliances and mixed collateral loan transactions in the real estate and financial services industries. We are positioned in a unique space in that my many years in big firm law and my expertise in complex mixed collateral transactions, mergers and acquisitions, private funds, fintech and bank regulation allow […]
Continue reading →The Dodd-Frank statute also led to the adoption of Regulation 15G of the Securities and Exchange Act of 1934 (15 U.S.C.A. § 78o-11), which requires the sponsor in a CMBS securitization to retain a 5% stake in the credit risk of the underlying commercial real estate asset. The purported purpose of the regulations is to […]
Continue reading →What’s Next? Some experts in the financial services industry, believe that the new Trump administration may change or roll-back a portion of the Dodd-Frank legislation. Financial institutions, mortgage companies, securitization sponsors, etc. must continue to treat current regulatory requirements as applicable to the business. It is important to differentiate the commitment to protection of consumers […]
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