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Qualified Mortgage Rule

Alston & Bird

Structured Finance Spectrum – Winter 2024

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Welcome to the latest edition of the Spectrum, covering hot-topic issues in the structured finance markets in the U.S. and UK. This edition features the shifting single-family rental landscape, what’s next for EDGAR, and...more

Alston & Bird

Complying with the “Consider” Requirement Under the Revised Qualified Mortgage Rules

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The originators of residential mortgage loans are inconsistent in meeting the “consider” requirement under the revised qualified mortgage rules. Our Financial Services & Products Group offers guidance for creditors looking to...more

Troutman Pepper

CFPB Announces Annual Threshold Adjustments for Credit Cards and Mortgages

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The Consumer Financial Protection Bureau (CFPB) has issued a final rule adjusting the Truth in Lending Act (TILA) dollar amounts for certain provisions, including under the Home Ownership and Equity Protection Act of 1994...more

Orrick, Herrington & Sutcliffe LLP

CFPB adjusts annual dollar amount thresholds under TILA, HMDA regulations

On December 21, the CFPB released a final rule revising the dollar amounts for provisions implementing TILA and its amendments that impact loans under the Home Ownership and Equity Protection Act of 1994 (HOEPA) and qualified...more

Ballard Spahr LLP

CFPB Issues Factsheet Addressing Prepaid Interest for Certain QM Loan APR Calculations

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The CFPB recently issued a factsheet addressing how prepaid interest, also referred to as per diem interest, factors into the calculation of the annual percentage rate (APR) for certain adjustable rate mortgage (ARM) loans...more

Ballard Spahr LLP

CFPB publishes annual CARD Act, HOEPA, QM adjustments (UPDATED)

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The CFPB recently 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

Alston & Bird

The QM Patch Is Down for the Count

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Somehow, the qualified mortgage (QM) rules have become even more complicated. Our Financial Services & Products Group parses how the death of the QM Patch will affect creditors seeking to originate residential mortgage loans...more

Nutter McClennen & Fish LLP

Nutter Bank Report: May 2021

Court Rules that Debt Collector Violated FDCPA with Communication to Dunning Vendor - A federal appellate court has recently ruled that a debt collector violated certain privacy requirements under the federal Fair Debt...more

Troutman Pepper

CFPB Issues Rule Delaying the Mandatory Compliance Date of the New General Qualified Mortgage Final Rule

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On April 27, the Bureau of Consumer Financial Protection (CFPB) issued a final rule to delay the mandatory compliance date for the General QM Final Rule until October 1, 2022. The CFPB stated that it issued the rule “to help...more

Wiley Rein LLP

Wiley Consumer Protection Download (May 10, 2021)

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Welcome to Wiley’s update on recent developments and what’s next in consumer protection at the Consumer Financial Protection Bureau (CFPB) and Federal Trade Commission (FTC). In this newsletter, we analyze recent regulatory...more

Manatt, Phelps & Phillips, LLP

Consumer Mortgages: Why the CFPB’s QM Rule Compliance Delay Isn’t Quite What It Seems

As proposed back in March, the Consumer Financial Protection Bureau (CFPB or Bureau) has now formally delayed the mandatory compliance date for the new general qualified mortgage (QM) rule to October 1, 2022, effective June...more

Goodwin

OCC Grants National Trust Bank Charter to Third Cryptocurrency Firm

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In This Issue. The Office of the Comptroller of the Currency (OCC) granted preliminary conditional approval to a third cryptocurrency firm chartering a national trust bank; the Consumer Financial Protection Bureau (CFPB)...more

Troutman Pepper

Troutman Pepper Weekly Consumer Financial Services COVID-19 Newsletter - May 2021

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Like most industries today, Consumer Finance Services businesses are being significantly impacted by the novel coronavirus (COVID-19). Troutman Pepper has developed a dedicated COVID-19 Resource Center to guide clients...more

Nutter McClennen & Fish LLP

Nutter Bank Report: April 2021

CFPB Takes Steps to Avoid a Possible Wave of Home Mortgage Loan Foreclosures - The CFPB has issued guidance to mortgage servicers, including banks that service mortgage loans for third-party noteholders, that the CFPB...more

Morgan Lewis - All Things FinReg

CFPB Finalizes Delay of Mandatory Compliance Date for General Qualified Mortgage Final Rule

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

Ballard Spahr LLP

CFPB Delays Mandatory Compliance Date of New General Qualified Mortgage Rule

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The CFPB recently issued a final rule delaying the mandatory compliance date for the new general qualified mortgage (QM) rule based on an annual percentage rate (APR) limit from July 1, 2021 to October 1, 2022. The final rule...more

Alston & Bird

Fannie Mae and Freddie Mac Sunset the QM Patch

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The qualified mortgage (QM) rules have become a world of contradictions. Our Financial Services & Products Group investigates how the residential mortgage markets can thread the needle between new rulings from Fannie Mae and...more

Ballard Spahr LLP

Fannie Mae and Freddie Mac Announce Plans to Purchase Only New General Qualified Mortgage Loans

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As previously reported, the CFPB proposed to delay the mandatory compliance date for the new general qualified mortgage (QM) rule that amends the Regulation Z ability to repay/QM rule from July 1, 2021 to October 1, 2022....more

Hudson Cook, LLP

CFPB Bites of the Month - March Top 10

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Each month, we host a 30-minute webinar outlining the month's key announcements and takeaways from the Consumer Financial Protection Bureau (CFPB) for financial services providers to consider. In this month's article, we...more

Nutter McClennen & Fish LLP

Nutter Bank Report: March 2021

Federal Reserve Issues New Guidance on Managing the LIBOR Transition - The Federal Reserve has issued guidance on how examiners will assess a banking organization’s progress in preparing to transition to a replacement rate...more

Alston & Bird

Evaluating the CFPB’s Proposed Delay of the QM Rule: Timing Considerations

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A&B ABstract: The CFPB must finalize its proposed QM delay rule in April, likely leaving no room for delay. Background on ATR/QM and the Delay Rule - On March 3, 2021, the Bureau of Consumer Financial Protection (CFPB)...more

Spilman Thomas & Battle, PLLC

All Consuming - Financial Litigation Insights, Volume 2, Issue 5

Biden Administration May Undo Certain Trump-Era Mortgage Rules - "Consumer advocates believe the rules may promote the sort of risky borrowing that led to the financial crisis in 2008." Why this is important: The...more

Troutman Pepper

CFPB Proposes to Delay the Mandatory Compliance Date of the New General Qualified Mortgage Final Rule

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On February 23, the Consumer Financial Protection Bureau (CFPB) issued a statement that it planned to propose a rule to “delay the July 1, 2021 mandatory compliance date of the General QM Final Rule.” Consistent with that,...more

Goodwin

SEC Releases 2021 Examination Priorities

Goodwin on

In this Issue. The U.S. Securities and Exchange Commission (SEC) Division of Examinations released its 2021 Examination Priorities and issued a risk alert noting that “Digital Asset Securities” entail characteristics and...more

Ballard Spahr LLP

CFPB Proposes To Delay Mandatory Compliance Date For New General Qualified Mortgage

Ballard Spahr LLP on

The CFPB has proposed to delay the mandatory compliance date for the new general qualified mortgage (QM) rule that amends the Regulation Z ability to repay/QM rule from July 1, 2021 to October 1, 2022. As previously...more

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