CFPB Proposed Clarifications on Qualified Mortgage Rules

Orrick - Finance 20/20
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On April 19, the CFPB released proposed rule amendments to the ability to repay/qualified mortgage (QM) rules. The proposals address: (i) clearer rules for determining DTI; (ii) confirmation regarding loans meeting eligibility requirements; (iii) that certain GSE or agency requirements do not impact the determination of QM status; (iv) that there is no field preemption under Regulation X; and (v) which mortgage loans to consider in determining whether a servicer qualifies as a ‘small servicer.’ Comments on the proposed amendments must be received within 30 days of publication in the Federal Register. CFPB Release. Proposed Rules.

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