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Ability-to-Repay Fair Lending

Ballard Spahr LLP

CFPB issues Fall 2019 Semi-Annual Report to Congress

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The CFPB has issued its Fall 2019 Semi-Annual Report to Congress covering the period April 1, 2019 through September 30, 2019. ...more

Ballard Spahr LLP

House Financial Services Committee: “rent-a-bank” hearing on Feb. 5; Director Kraninger to testify on Feb. 6

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On Wednesday, February 5, the House Financial Services Committee will hold the first part of a two-part hearing on “rent-a-bank” structures. The hearing is titled “Rent-A-Bank Schemes and New Debt Traps: Assessing Efforts to...more

Ballard Spahr LLP

CFPB publishes Spring 2019 rulemaking agenda

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The CFPB has published its Spring 2019 rulemaking agenda as part of the Spring 2019 Unified Agenda of Federal Regulatory and Deregulatory Actions, which is coordinated by the Office of Management and Budget (OMB).  ...more

Skadden, Arps, Slate, Meagher & Flom LLP

Consumer Financial Protection Bureau Update

A degree of uncertainty hangs over the Consumer Financial Protection Bureau (CFPB) following the November 2017 resignation of its first director, Richard Cordray. On his last day in office, Cordray appointed his chief of...more

Ballard Spahr LLP

CFPB Spring 2017 Supervisory Highlights focuses on mortgage origination/servicing, student loan servicing deficiencies, service...

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The CFPB’s newly-released Spring 2017 edition of Supervisory Highlights covers supervisory activities generally completed between September and December 2016. The report indicates that supervisory resolutions resulted in...more

Ballard Spahr LLP

CFPB previews 5-year review of mortgage rules

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Dovetailing with President Trump’s recent Executive Order requiring a reduction in regulatory burden, on March 21, 2017, a CFPB official remarked at the American Bankers Association Government Relations Summit that the CFPB...more

Ballard Spahr LLP

CFPB issues Fall 2016 Supervisory Highlights

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In its Fall 2016 Supervisory Highlights, which covers supervision work generally completed between May and August 2016, the CFPB highlights violations found by its examiners involving origination and servicing of auto...more

Morrison & Foerster LLP

A Closer Look at the CFPB’s Proposed Short-Term Lending Rule

As we previously reported in our June 3, 2016 client alert, the Consumer Financial Protection Bureau (“CFPB”) has issued a Notice of Proposed Rulemaking for short-term loans (“Proposed Rule”). In this follow-up alert, we take...more

Goodwin

Federal Banking Agencies Issue Interagency Statement on Supervisory Approach to Qualified Mortgage Loans

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The FDIC, OCC, NCUA and FRB issued an interagency statement on the supervisory approach to originating qualified mortgages under the CFPB’s ability-to-repay and qualified mortgage rule finalized in January 2013 and...more

Goodwin

Federal Regulators Issue Statement on Fair Lending Compliance and the Ability-to-Repay and Qualified Mortgage Rules

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In response to inquiries from creditors about liability under the Equal Credit Opportunity Act’s disparate impact doctrine on originating qualified mortgages under the CFPB’s ability-to-repay provisions, the CFPB, OCC, FRB,...more

Morrison & Foerster LLP

Interagency Fair Lending Guidance: A First Step, but in the Right Direction?

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Five federal regulators, with HUD noticeably absent, issued the first interagency guidance on the much-debated intersection of fair lending enforcement and the Ability-to-Repay and Qualified Mortgage Standards Rule taking...more

Ballard Spahr LLP

CFPB joins interagency statement on qualified mortgage fair lending risks

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The CFPB was one of five federal regulators issuing an interagency statement intended to address industry concerns regarding the fair lending risks associated with compliance with the CFPB’s ability-to-repay/qualified...more

Ballard Spahr LLP

Federal Regulators Issue Statement on Qualified Mortgage Fair Lending Risks

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Federal regulators have issued an interagency statement intended to address industry concerns regarding the fair lending risks associated with compliance with the Consumer Financial Protection Bureau’s...more

Dechert LLP

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

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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

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