Jon David D. Langlois
Partner
Biography
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.
Publications
"Compliance considerations after OCC ups fintech scrutiny" by Jon David D. Langlois, Max Bonici, and Marisa Perfetti (Law360)
The Office of the Comptroller of the Currency recently noted bank-fintech partnerships as a key element of its fiscal year 2023 bank supervision operating plan, putting both OCC-supervised depository institutions and fintech companies looking to partner with them on notice that their relationships...
Articles"Opinion: How mortgage servicers can prepare for a crackdown from the CFPB” by Sasha Leonhardt, Jon David D. 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...
ArticlesJeffrey 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...
ArticlesSpecial Alert: Election Results - Preliminary Thoughts and Reactions
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...
ArticlesSpecial 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...
ArticlesSpecial Alert: CFPB Finalizes Amendments to Mortgage Servicing Rules
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...
ArticlesVendor Management in 2015 and Beyond
With evolving regulatory expectations and increased enforcement exposure, financial institutions are under more scrutiny than ever. Nowhere is this more evident than in the management and oversight of service providers. When service providers are part of an institution’s business practice,...
ArticlesConsumer Financial Services Answer Book 2016
The fifth edition of the Practising Law Institute’s Consumer Financial Services Answer Book was published this month, with 29 Buckley Sandler attorneys contributing to this leading desk reference. The 2016 edition of the Consumer Financial Services Answer Book continues to provide practitioners...
ArticlesSpecial Alert: CFPB Bulletin Re-Emphasizes Focus on Mortgage Servicing Transfers
On August 19, 2014, the CFPB issued Bulletin 2014-01 to address “potential risks to consumers that may arise in connection with transfers of residential mortgage servicing rights.” The bulletin, which is the latest in a series of CFPB regulations, statements, and guidance on this subject, replaces...
ArticlesSpecial Alert: Federal Reserve Board Guidance on Managing Outsourcing Risks Mirrors Recent OCC Guidance
On December 5, 2013, the Federal Reserve Board (FRB or the Fed) issued Supervision and Regulation Letter 13-19 , which details and attaches the Fed’s Guidance on Managing Outsourcing Risk (FRB Guidance). The FRB Guidance sets forth risks arising out of the use of service providers and the...
ArticlesSpecial Alert: OCC Updates Third-Party Risk Management Guidance
On October 30, the OCC issued Bulletin 2013-29 to update guidance relating to third-party risk management. The Bulletin, which rescinds OCC Bulletin 2001-47 and OCC Advisory Letter 2000-9, requires banks and federal savings associations (collectively “banks”) to provide comprehensive oversight of...
ArticlesSpecial Alert: CFPB Finalizes Additional Amendments to ATR/QM Rule; Agencies Propose Appraisal Rule Amendments
On July 10, the Consumer Financial Protection Bureau (“Bureau”) finalized important amendments (the “Amendments”) to its ability-to-repay / qualified mortgage rule (the “QM / ATR Rule”) that are intended to ease certain compliance challenges with making qualified mortgages (“QMs”). In response to...
Articles
Education
- J.D., Georgetown University, 2005
- B.A., University of Richmond, 1997
Admissions
- District of Columbia
- Maryland
Memberships & Involvements
- Member, Maryland Bar Association