The Consumer Financial Protection Bureau, which inherited RESPA enforcement from HUD, has been leaning on this test in such enforcement actions of its own.
The HUD NPL auction features 5,000 delinquent single-family loans totaling $1 billion in unpaid principal balances with representations and warranties.
In other subprime news, industry veteran Jon Daurio was recently in New York talking to potential investors about his new nonbank venture, Nikkael Capital Corp.