A previous client alert examined the potential implications of the CFPB’s new mortgage rules in light of HUD’s recent clarification on how it will apply the statistical disparate impact approach to fair housing enforcement. That article examines the potential conflict between the two rules and concludes that bankers who attempt in good faith to comply with the new mortgage rules by making only “Qualified Mortgages” will be at high risk for a fair housing / fair lending enforcement action.
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