Legal Seminar, Chicago, IL

Resolution Strategy

• Implementation Strategy – Administrative Actions : timing and remedies coordinated between states

– Receivership : Utilize common law receivership remedies and Dodd-Frank precedent in New York Department of Financial Services’ successful court-appointed receivership over a large nonbank lender – Bankruptcy : States file motions to protect their regulatory interests and preserve a role with the trustee

• For each resolution mechanism, the Resolution Guide has a defined and detailed process for States to follow proceeding in multiple phases.

• Facts will dictate legal course of action. Path to resolution likely to include multiple legal courses of action.

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Improved Data & Analytics

• Improvements to data and analytics capabilities remains critical to enhancing supervisory oversight

• Mortgage Origination Examination Report allows peer group analysis of a mortgage originator’s portfolio

• Mortgage Servicer Examination Report is developed and in use

• Development of the Nationwide Multistate Licensing System (NMLS) 2.0 – Enable the collocation of exam reports and MCR data in one secure environment. – Enable historical analysis and assessment of supervisory examination findings to enhance supervisory processes

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