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Thomas P. Vartanian

Thomas P. Vartanian

Dechert LLP


Latest Publications

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American Bankers Association Real Estate Lending Conference - Qualified Mortgages: A Sea Change For Mortgage Lenders

In This Presentation: - The Qualified Mortgage (QM) Rule - Small Creditor QM Proposal - The Ability-to-Repay (ATR) Rule: What It Says and What It Means - Liability for Failure to Comply with the ATR and QM...more

4/16/2013 - Ability-to-Repay CFPB Disparate Impact Fair Lending HUD Lenders Loans Mortgages Qualified Mortgage Rule Safe Harbors Underwriting

2012 Bank Enforcement Actions Still High, But Significantly Lower Than 2010-11

Originally published in BNA’s Banking Report, 100 BBR 617 on 04/02/2013. Overall Trends & Outlook - In 2012, the federal banking agencies, including the Federal Deposit Insurance Corporation (‘‘FDIC’’), Office...more

4/4/2013 - Anti-Money Laundering CFPB Enforcement Actions Fair Lending FCRA FDIC FinCEN Mortgage Reform OCC OFAC Unfair or Deceptive Trade Practices

U.S. Department of Housing and Urban Development Issues Final Rule Affirming Use of Disparate Impact to Establish Liability for...

The U.S. Department of Housing and Urban Development (“HUD”) issued a final rule (“Rule”) on February 8, 2013, which provides additional support to potential government and private plaintiffs seeking to challenge “facially...more

2/15/2013 - Burden of Proof Burden-Shifting Discriminatory Effects Rule Disparate Impact FHA HUD Legally Sufficient Justification

U.S. Consumer Financial Protection Bureau Seeks Comments to Proposed Amendments to the Ability-to-Repay Requirements and Qualified...

The U.S. Consumer Financial Protection Bureau (the “Bureau”) has released a proposal (the "Proposal") to amend the Bureau's recently issued final rules (the “Rules”) on the definition of a qualified mortgage (“QM”) and the...more

2/15/2013 - Ability-to-Repay Additional Classes of QM CFPB Exemptions Mortgages Qualified Mortgage Rule Rebuttable Presumption Threshold Safe Harbors

U.S. Consumer Financial Protection Bureau Issues Rules on Qualified Mortgages and Ability to Repay

Congress in the Dodd-Frank Act responded to concerns about the quality of mortgage loans by establishing incentives for lenders to seek to ensure that borrowers had the ability to repay mortgage loans made to them. In...more

1/16/2013 - Ability-to-Repay Borrowers CFPB Damages Dodd-Frank Foreclosure Lenders Loans Mortgages Penalties Qualified Mortgage Rule Rebuttable Presumptions Safe Harbors TILA

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