Rescission of 2015 MSA Compliance Bulletin Further Evidence of CFPB's Gentler RESPA Section 8 Approach - But New FAQs Do Not Necessarily Provide More Comfort

On October 7, 2020, the CFPB announced that it was "provid[ing] clearer rules of the road for RESPA marketing service agreements" in the mortgage industry by rescinding its 2015 guidance regarding marketing services agreements (MSAs) and issuing Frequently Asked Questions(FAQs) on Real Estate Settlement Procedures Act (RESPA) Section 8 topics, including FAQs addressing how RESPA Section 8 and the corresponding provisions of Regulation X apply to MSAs....
By: Davis Wright Tremaine LLP

Array