Richard J. Andreano, Jr.

Richard J. Andreano, Jr.

Ballard Spahr LLP

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CFPB’s fact vs. fiction guide: useful information for consumers or defense planning?

With the January 10 effective date imminent, the CFPB has issued what it labels a “fact vs. fiction guide” on its ability-to-repay/qualified mortgage rule. According to the CFPB, the guide is intended “to help dispel some of...more

1/8/2014 - Borrowers CFPB Lenders Mortgages Qualified Mortgage Rule Real Estate Market

CFPB joins interagency statement on qualified mortgage fair lending risks

The CFPB was one of five federal regulators issuing an interagency statement intended to address industry concerns regarding the fair lending risks associated with compliance with the CFPB’s ability-to-repay/qualified...more

10/25/2013 - Ability-to-Repay CFPB Fair Lending FDIC Federal Reserve Mortgages NCUA OCC Qualified Mortgage Rule

Federal Regulators Issue Statement on Qualified Mortgage Fair Lending Risks

Federal regulators have issued an interagency statement intended to address industry concerns regarding the fair lending risks associated with compliance with the Consumer Financial Protection Bureau’s...more

10/25/2013 - Ability-to-Repay CFPB Fair Lending FDIC Mortgages NCUA Qualified Mortgage Rule

Director Cordray comments on timing of further mortgage rule changes and enforcement approach

While Director Cordray mostly recycled comments he has previously made about the CFPB’s mortgage rules in his remarks today to the American Mortgage Conference, he did offer some newsworthy information....more

9/11/2013 - CFPB Enforcement Mortgages Qualified Mortgage Rule Richard Cordray

CFPB finalizes additional revisions to mortgage rules

On July 10, 2013, the CFPB issued a final version of modifications proposed in April 2013 to mortgage rules adopted in January 2013. Most of the modifications address the ability to repay/qualified mortgage rule, and...more

7/15/2013 - Borrowers CFPB Creditors Department of Agriculture Fannie Mae Freddie Mac Lenders Mortgages Qualified Mortgage Rule

CFPB issues final 2014 list of rural or underserved counties

The CFPB has released a final list of “rural” or “underserved” counties for use in 2014. The CFPB has indicated that creditors may rely on this list as a safe harbor to determine whether a county is “rural” or “underserved”...more

7/9/2013 - Ability-to-Repay CFPB Creditors HOEPA Loans Mortgage Escrow Account Qualified Mortgage Rule Safe Harbors

CFPB Proposes Changes to Ability-To-Repay, Servicing Rules

In keeping with its promise to provide further guidance to the industry on the recent mortgage loan rules, the Consumer Financial Protection Bureau recently proposed clarifications and changes to the...more

4/26/2013 - Ability-to-Repay CFPB Mortgage Servicing Rules Mortgages Qualified Mortgage Rule

CFPB issues Small Entity Compliance Guide for ability to repay mortgage rule; trade groups seek more time for implementation

The CFPB has issued a Small Entity Compliance Guide on the ability to repay and qualified mortgage rule. According to the 45-page guide, it is intended to provide “an easy-to-use summary” of the rule and “highlights issues...more

4/11/2013 - CFPB Mortgages Qualified Mortgage Rule Small Entity Compliance Guide

Qualified mortgage remorse?

Could the CFPB be worried that its ability-to-repay/qualified mortgage rule is already contracting the availability of mortgage credit? In his remarks earlier this week to the Credit Union National Association, Director...more

3/1/2013 - CFPB Mortgages Qualified Mortgage Rule

CFPB announces mortgage rules implementation plan

The CFPB has announced various steps it plans to take over the next year to support the industry’s implementation of the mortgage rules issued in January 2013 and which take effect in January 2014. Those rules include the new...more

2/14/2013 - Ability-to-Repay CFPB Mortgage Servicing Rules Mortgages Qualified Mortgage Rule

Quoth the CFPB: “Nevermore” on loans made to consumers who can’t repay

On January 10, 2013, the CFPB issued the long-awaited ability to repay/qualified mortgage rule and, while the devil will be in the details, it appears that cautious optimism for the mortgage industry is warranted....more

1/14/2013 - CFPB Qualified Mortgage Rule Safe Harbors

CFPB Final Ability-To-Repay Rule Prompts Cautious Optimism from Industry

The CFPB has issued its long-awaited ability to repay/qualified mortgage rule, and at first glance, it appears to warrant cautious optimism for the mortgage industry....more

1/14/2013 - Ability-to-Repay Borrowers CFPB Dodd-Frank Loans Mortgages Qualified Mortgage Rule Refinancing Underwriting

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