Jon Langlois has focused his career on representing financial institutions and financial services providers on critical transactional and regulatory compliance matters, developing a particular focus on mortgage lending and servicing activities. A Partner in the Washington, D.C., office of Buckley LLP, Mr. Langlois represents banks, nonbanks, fintechs, private equity, and other financial services companies in a variety of corporate and transactional matters, particularly those involving residential mortgage and consumer loans, mortgage servicing rights, and servicing and subservicing relationships. He combines practical strategic advice with a deep knowledge of consumer lending and servicing to provide efficient, successful results.
Representative transactional work includes:
- Negotiating sales of whole loans and mortgage servicing rights (MSRs), both private and government-sponsored enterprise (GSE), as well as consumer loans
- Negotiating servicing and subservicing agreements and other outsourcing transactions with third-party service providers
- Advising on selling and servicing relationship issues with Fannie Mae, Freddie Mac, and Ginnie Mae
- Arranging secured financing transactions, including warehouse lines and advance and buyout facilities
- Advising on bank partnership and other marketplace lending transactions
- Developing compliant MSR recapture structures
In addition to his transaction practice, Mr. Langlois assists clients on a wide range of regulatory issues, including compliance with key consumer financial laws, such as the Truth in Lending Act (TILA), Real Estate Settlement Procedures Act (RESPA), Fair Debt Collection Practices Act (FDCPA), unfair, deceptive, and abusive acts and practices (UDAAP), and other consumer protection issues.
- Preparing institutions for, and guiding institutions through, supervisory examinations by the Consumer Financial Protection Bureau (CFPB), the Office of the Comptroller of the Currency (OCC), the Federal Reserve Board (FRB) and other regulatory agencies
- Designing compliant mortgage servicing processes, particularly with respect to loss mitigation and foreclosure prevention
- Developing third party oversight/vendor oversight programs and compliance management systems
- Conducting due diligence reviews of key providers for acquisitions or significant engagements
- Advising on appraisal issues, including appraiser independence and compliance with interagency appraisal guidelines
- Addressing transitions away from LIBOR-based obligations
Mr. Langlois received his J.D. from Georgetown University and his B.A. from the University of Richmond. While in law school, he was a Legislative Analyst with Wilmer Cutler Pickering Hale and Dorr, and a Government Affairs Representative with the American Financial Services Association.
"Opinion: How mortgage servicers can prepare for a crackdown from the CFPB” by Sasha Leonhardt, Jon Langlois, and David McGee (National Mortgage News)
The Consumer Financial Protection Bureau is drawing a line in the sand for the mortgage servicing industry with new guidance and proposed revisions to its mortgage servicing rules. The CFPB expects that the impending expiration of federal foreclosure and forbearance protections for mortgagees will...Articles
"Debt collection, convenience fees, and the FDCPA" by Jon David D. Langlois and Elizabeth R. Bailey (The Review of Banking & Financial Services)
In the era of online banking and the Internet of Things, the ability to pay your mortgage in a manner other than sending in a paper check evidences both convenience and complication. Convenience to the borrower, in that there are many avenues to quickly make a payment, even a late payment, to avoid...Articles
Jeffrey P. Naimon and Jon David D. Langlois Authored a Law360 Article, "Ignore Borrower Preference In Loss Mitigation? CFPB Says Yes"
Mortgage servicers should not listen to borrowers when it comes to loss mitigation. At least, that’s what the Consumer Financial Protection Bureau says. More specifically, servicers should disregard when a borrower tells the servicer they do not want to keep their home. Officially, this has been...Articles
As a result of last Tuesday’s election, Republicans will control the White House and both houses of Congress in 2017. It is likely there ultimately will be some significant changes affecting financial services regulation and enforcement, but they will take time to implement. The President-elect has...Articles
Special Alert: D.C. Circuit Panel Rejects CFPB's RESPA Interpretation and Alters its Structure in PHH Corp. v. CFPB
On October 11, a three-judge panel of the U.S. Court of Appeals for the District of Columbia Circuit issued an opinion vacating a $109 million penalty imposed on PHH Corporation under the anti-kickback provisions of the Real Estate Settlement Procedures Act (RESPA), concluding that the CFPB...Articles
On August 4, the CFPB issued its long-awaited final amendments to the mortgage servicing provisions of Regulations X and Z. The Bureau had sought comment on the proposed rule in December 2014, more than 18 months ago. Spanning 900 pages, the final rule makes significant changes that will impact...Articles