Episode 25: 10 Factors That May Hinder a Contractor’s Ability to Repay Its Bank Loans and Threaten Its Existence
Critical Mortgage Regulatory Updates by the Consumer Financial Protection Bureau for 2013 and 2014
The CFPB recently issued a Request for Information Regarding Mortgage Refinances and Forbearances (RFI) Comments on the RFI will be due 60 days after publication in the Federal Register....more
On April 27, 2021, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a final rule formally delaying the mandatory compliance date for the rule defining a “qualified mortgage” (QM) (the General QM Final Rule)...more
CFPB Acting Director Warns of Enforcement on ‘Ability to Repay’ and Residential Evictions - In two recent communications, the Consumer Financial Protection Bureau (CFPB or Bureau) acting director is signaling that the...more
We previously reported on recent mortgage rulemakings that were finalized by the Consumer Financial Protection Bureau (CFPB or Bureau) late last year. Of the two final rules from the Bureau, one drastically simplifies the...more
The Consumer Financial Protection Bureau (CFPB) recently published two final rules revising its Ability-to-Repay/Qualified Mortgage Rule (ATR/QM Rule). The principal purpose of these final rules is to avoid anticipated...more
In anticipation of the “GSE patch” expiring, the Consumer Financial Protection Bureau (“CFPB”) issued several final rules in 2020 to amend Regulation Z (“Reg. Z”). Concerns have existed that the expiration of the GSE patch...more
On August 18, 2020, the Consumer Financial Protection Bureau (CFPB) issued a proposed rule to create a new category of loans known as “seasoned” qualified mortgages (Seasoned QMs). This new category of qualified mortgages...more
The Consumer Financial Protection Bureau (CFPB or Bureau) issued a proposed rule on August 18 to create a new category of seasoned qualified mortgages (Seasoned QMs) that, if finalized as written, would carry significant...more
On August, 18, 2020, the CFPB issued a new proposed rule to create a new category of “seasoned qualified mortgages” (Seasoned QMs) that would receive the safe harbor conclusive presumption of meeting the Ability to Repay...more
The Consumer Financial Protection Bureau on June 22 issued two proposed rules with significant implications for the mortgage marketplace....more
The CFPB recently proposed a temporary extension of the qualified mortgage (QM) that is based on a loan being eligible for sale to Fannie Mae or Freddie Mac (often referred to as the “GSE Patch”). ...more
Late last month the CFPB reignited debate when it issued an Advance Notice of Proposed Rulemaking (“ANPR”) stating its intention to allow the “GSE Patch” to expire in January 2021. The GSE Patch allows what would otherwise...more
Sometimes common sense rules the day. Our Financial Services & Products Group discusses a case of first impression in Ohio that will allow the mortgage industry to rely on the Consumer Financial Protection Bureau’s...more
On January 10, 2019, the CFPB issued a press release regarding two recently-released reports, which analyze the efficacy of the Ability to Repay Rule (ATR), and the RESPA Servicing Rule (Servicing Rule). The assessment...more
Late last month, President Trump’s administration released a wide-sweeping reform and reorganization plan for the federal government. Included in this plan was a proposal to reform two of the largest government sponsored...more
The CFPB has published a final rule regarding various annual adjustments it is required to make under provisions of Regulation Z (TILA) that implement the CARD Act, HOEPA, and the ability to repay/qualified mortgage...more
In our initial article announcing our top 10 considerations for financial institutions in 2016, our eighth consideration was the Ability to Repay rules. This is another of the areas the Consumer Financial Protection Bureau...more
The CFPB’s ability-to-repay (ATR) rule became effective in January 2014. It requires mortgage lenders to determine during underwriting that a borrower has a reasonable ability to repay a loan according to its terms. ...more
On September 21, the Consumer Financial Protection Bureau (CFPB) finalized several changes to its mortgage rules to increase the number of financial institutions able to offer certain types of mortgages in rural and...more
The CFPB has issued a final rule that revises the definitions of “small creditor” and “rural areas” under Regulation Z of the Truth in Lending Act (TILA). The final rule is effective January 1, 2016. We previously reported on...more
Why it matters - Seeking to reassure smaller financial institutions struggling to cope with regulatory changes in the mortgage industry, the Consumer Financial Protection Bureau (CFPB) proposed changes intended to...more