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Volume 25 - Number 20

September 29, 2014

Worth Noting/Legislative Update/Looking Ahead

Did Apple Place Itself Within CFPB’s Purview? Some legal experts think the recent rollout of mobile payment technology by Apple Inc. might have put the consumer technology heavyweight in the CFPB’s regulatory crosshairs. Georgetown Law Professor Adam Levitin said in a recent blog that Apple may have unwittingly become a regulated financial institution through the release of its Apple Pay service. “Basically, I think Apple is now a ‘service provider’ for purposes of the Consumer Financial Protection Act, which means Apple is subject to CFPB examination and UDAAP [unfair, deceptive or abusive acts or practices],” he said. Levitin then proceeded to walk readers through a number of legal definitions to bolster his argument. Vivian Kim, an associate at the Dykema ...

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HUD has announced a 25 basis point cut in FHA premiums, which is slated to take effect in late January. Is your lending shop for or against a cut in FHA premiums?

For. It should help lending volumes.
Against. The private MI sector should take on this risk, not the government.
Too early to say.
I believe the new White House may scuttle the idea so it doesn’t matter.

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