Allison Botos Schilz assists clients in navigating the challenges of the post-Dodd Frank Act regulatory environment, focusing on issues affecting the primary and secondary mortgage markets. Allison focuses on regulatory and compliance matters affecting the consumer financial services industry.
She advises financial institutions, mortgage lenders and servicers, community banks, REITS, investment firms and other industry participants on a variety of regulatory compliance, licensing and transactional issues.
Allison regularly advises clients on a wide range of consumer financial laws and regulations, including the Real Estate Settlement Procedures Act (RESPA), the Truth in Lending Act (TILA) and the Fair Credit Reporting Act (FCRA).
She provides counsel on federal agency and investor requirements, including FHA, VA, Fannie Mae and Freddie Mac. She helps clients prepare for and respond to state and federal regulatory audits and examinations, including the Consumer Financial Protection Bureau (CFPB) and HUD.
Allison has extensive experience in state mortgage licensing on a nationwide basis, including requirements under the Secure and Fair Enforcement for Mortgage Licensing (SAFE) Act and use of the Nationwide Multistate Licensing System (NMLS).
She provides licensing advice to mortgage lenders, brokers, servicers, debt collectors and investors in whole loans and mortgage servicing rights (MSRs).
She acts as regulatory counsel in transactions involving mortgage industry participants, providing strategic advice on federal and state change of control requirements and conducting regulatory due diligence on behalf of investors.
- Advised clients on various CFPB rules, including the Ability-to-Repay/Qualified Mortgage Rule (ATR/QM Rule), the Loan Originator Compensation Rule (LO Comp), the TILA-RESPA Integrated Disclosure Rule (TRID), and the mortgage servicing rules under RESPA and TILA.
- Advised mortgage industry participants on various arrangements under RESPA Section 8, marketing services agreements, co-marketing, desk rentals, lead sales and related arrangements.
- Advised a secondary market investor on regulatory compliance issues applicable to “fix and flip” and investor loans.
- Acted as regulatory counsel for an investment management firm acquiring an interest in a mortgage services provider.
- Assisted a mortgage lender and servicer in developing a quality control plan to comply with the requirements of various federal agencies and GSEs, including FHA, VA, Fannie Mae and Freddie Mac.
- Assisted an investor with identifying and obtaining state licenses required to purchase and hold MSRs and structuring an excess servicing spread transaction.
- Advised a hedge fund in structuring a multiphase investment in a state-licensed mortgage company and assisted with obtaining the required state and federal regulatory approvals.
- Assisted a mortgage lender in applying for and securing Issuer approval from Ginnie Mae.
- Reviewed a mortgage lender’s website, advertising and marketing materials for compliance with federal and state laws and regulations.
- JD, Wake Forest University School of Law, 2006
- BA, University of Virginia, 2003
- District of Columbia
- North Carolina
- Member, District of Columbia Bar Association
- Member, Mortgage Bankers Association
- Member, American Bar Association Consumer Financial Services Committee
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