Ed. #111: Do Discounts Corrupt Absolutely?
Find a new way to criticize LO Comp? Hold my beer! As we open the Mortgage Bankers Associations’ 2026 Annual Conference in my hometown of Chicago,[1] my Chrisman Commentary friends reminded me that readers seem to enjoy Musings in which I complain about the Loan Originator Compensation Rule. Yet, after writing over half a dozen […]
Ed. #110: “I’m your Vehicle, Baby”
The MBA’s Fair Lending Challenge to New Jersey Brian S Levy Sep 07, 2026 Without restating all of my fair lending priors (which you can find in Musing #92 Disparate Impact’s Demise), in a footnote to a recent Musing about the Fair Housing Act’s “robust causality” standard I stated, “It would be enormously helpful to fair lending jurisprudence […]
Ed. #109: RESPA §8 Regulates Conflicts of Interest
And What That Means for RESPA Reform Two days after I co-hosted a lively collegial Mortgage Law Today[1] All-Star RESPA nerd panel putting RESPA’s Section 8[2] on the hot seat by asking whether we need RESPA at all, Brian Johnson[3] was put on the hot seat for his Senate Banking confirmation hearing to serve as CFPB Director. Although RESPA never […]
Ed. #108: In Praise of CFPB Humility
But Regulators Are Not Orcas These Musings have spent the better part of the past 6 ½ years expressing my frustration at the lack of regulatory humility demonstrated by the nation’s consumer financial regulator (CFPB). But something unprecedented in the CFPB’s relatively short history happened without much fanfare[1] in late May that deserves recognition and praise from this […]
Ed. #107: The Strait of Homer(z)
A couple months ago I was complaining about the lack of inspiration for my Musings, suggesting that CFPB is basically implementing (albeit with questionable durability), my preferred deregulatory guidance, leaving me uninspired. Well, thanks to current world events, a new movie on Homer’s The Odyssey, the CFPB and the Trump Administration , I’m offering this cynical take (highlighting my penchant […]
Ed. #106: Robust Causality & Fair Lending
What’s a mortgage compliance officer to do now? On a recent mortgage industry podcast, I was asked what mortgage originators should be doing today to be compliant with fair lending. I must admit, even after sitting through multiple fair lending panels at the MBA’s Legal Issues and Regulatory Conference (LIRC)[1] earlier this month with outstanding insights […]
Ed. #105: Irony, CFPB as Inspiration, and Market Power
Mortgage “Amusings” for long form readers Isn’t it ironic[1] Before Elizabeth Warren sounded alarms about the dangers of consumer finance in the US which led to the creation of the Consumer Financial Protection Bureau (CFPB) and the vast array of regulations that “protect” consumers from those evils, Ralph Nader was the most famous person shouting […]
Ed. #104: Safety in Numbers?
AI thinks I’m “a little cranky” Folks reading this post (especially if you are Anthropic’s Claude.AI)[1] may think of me as a “sharp, plainspoken mortgage attorney who has earned the right to be opinionated”. Alternatively, you may think I, “read like the smartest, most opinionated attorney at the industry conference — someone who has seen it all, […]
Ed. #103: Abolish the Credit Bureaus?
Yes, eliminate their role in credit reporting The phrase “Abolish ___” has been a cornerstone of social and political movements for centuries, used to demand the total elimination of specific institutions rather than their reform. Of course, “Abolish Slavery” was the mic drop use, but that still resonated when I heard the slogan, “Abolish Apartheid” […]
Ed #102: RESPA & “Reverse” Referrals
Is There Even a “Referral” Back at All? Dry January? We open 2026 after a couple short week holidays[1] and amid discussion of the inverted food pyramid and challenging efforts to achieve a “dry January”.[2] But, here at the Levy School of RESPA Compliance (LSRC), we like to invert your RESPA understandings and make RESPA anything but a dry […]
Mortgage Law Today WebShow 12/16/25
Reverse Mortgage Lending in the Spotlight