Koogler Group Regulatory Memos

Koogler Group Educational Memos on the
FinCEN Residential Real Estate Rule

• 03-23-2026: FinCEN Temporarily Suspends RRER Filing Requirement
• 03-19-2026: U.S. District Court Vacates and Sets Aside FinCEN Rule
• 02-14-2026: FinCEN Educational Update February 14, 2026
• 02-13-2026: FinCEN-Direct FAQs Update February 13, 2026
• 01-01-2026: FinCEN Report on Enhanced Life Estates, Title Insurance, and FinCEN
• 10-10-2025: Memo regarding extended FinCEN RULE effective date and future expiration date of the renewed FinCEN GTOs

Koogler Group Educational Memos on Regulatory Initiatives to Waive Title Coverage and/or Replace Loan Policies with AOLs

Information provided to the Administration, US Treasury, FIO, FHFA, CFPB, and all NAIC Insurance Commissioners

• July 16, 2024 Educational Response on RFI Docket No. CFPB-2024-0021, Regulatory History of (Junk) “Fee Proliferation” and “Packaged Services”
• April 8, 2024 White House Memo
• December 9, 2022 Letter to Sandra Thompson, Director FHFA, Regarding ATO Product
• December 9, 2022 Letter to NAIC Task Force Regarding ATO Product

Koogler Group Educational Memos on Industry Impact of TRID Final Rule

Information provided to the CFPB, NAIC, State Attorneys General, and State Governors

• October 2016 Commentary to CFPB Regarding Sharing the Closing Disclosure: Privacy Issues and Provider Liability
• July 2016 Letter to NAIC Title Insurance Task Force Members re Educational Materials
• 2027 Karen E. Koogler Professional Biography with Student Comments
• December 2015 Letter to CFPB and State Insurance Commissioners regarding Title Insurance Premium, Seller Credits and other Issues of Concern under the TRID Rule
• Special Report: FutureFocus on the TRID Rule
• July 2015 Commentary to CFPB Regarding October 3, 2015 Effective Date and Impact of TRID Rule on Title (Settlement) Agents
• March 2015 Letter to State Governors, Insurance Commissioners, and Attorneys General regarding Title Insurance Treatment Under the Final Rule