The CFPB recently issued new guidance that warns mortgage brokers to avoid acting as mini-correspondents in an attempt to side-step consumer protection laws and disclose how much money they make on a transaction. The bureau is concerned that some mortgage brokers may be setting up arrangements with investors in which the broker claims to be a “mini-correspondent lender,” when in fact the broker is still essentially just facilitating a transaction between a borrower and a lender. In its new guidance, the agency sets out some of the questions the CFPB may consider in evaluating mortgage transactions involving mini-correspondent lenders in order to understand their true nature. This evaluation involves examining how the mini-correspondent lender is structured and operating. Among the ...