In This Issue:
- FEDERAL ISSUES
- STATE ISSUES
- FIRM NEWS
- FIRM PUBLICATIONS
- CONSUMER FINANCE
- PRIVACY/DATA SECURITY
- Excerpt from Federal Issues:
CFPB Issues Ability to Repay/Qualified Mortgage Rule and High-Cost Mortgage Rules. On January 10, the CFPB issued a rule that will require creditors to verify a consumer's ability to repay prior to making almost any type of mortgage loan. The rule defines a "qualified mortgage," providing a safe harbor from liability for loans with an APR below Regulation Z's "higher priced" threshold of 150 basis points above the Average Prime Offer Rate, and a "rebuttable presumption" for loans with an APR above that threshold. The rule will become effective on January 10, 2014. Concurrently, the CFPB released a proposal seeking comment on amendments to the final rule that would, among other things, provide exemptions for certain community-based lenders and small portfolio creditors and potentially change the treatment of indirect lender compensation for purposes of the qualified mortgage "points and fees" test. BuckleySandler has prepared a Special Alert that highlights a few key issues resolved and left open by the nearly 1,000-page releases on the rule and concurrent proposal. We will distribute a summary and additional analysis of key issues in the releases once we complete our review of them.
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Published In: Administrative Agency Updates, Finance & Banking Updates, Privacy Updates, Residential Real Estate Updates, Securities Updates
DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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