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
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
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
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
The CFPB recently issued a policy statement addressing the rules finalized near the end of former Director Kraninger’s tenure that amend the Regulation Z ability to repay rule/qualified mortgage (QM) requirements to replace...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
The Consumer Financial Protection Bureau (“CFPB”) recently issued two final rules aimed at bolstering the Qualified Mortgage (“QMs”) market. The first final rule amends the general eligibility category of QMs (“General QMs”)...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 December 10, the Consumer Financial Protection Bureau (CFPB) issued two final rules related to qualified mortgage (QM) loans. The first final rule, the General QM Final Rule, replaces current requirements for measuring a...more
The Consumer Financial Protection Bureau (“CFPB”) issued two relatively welcome surprises yesterday. First, along with ditching a debt-to-income ratio (“DTI”) ceiling, the agency expanded its proposed general Qualified...more
The CFPB recently issued a final rule amending Regulation Z ability to repay rule/qualified mortgage (QM) requirements to replace the strict 43% debt-to-income (DTI) ratio basis for the general QM with an annual percentage...more
The Consumer Financial Protection Bureau (Bureau or CFPB) issued two final rules on December 10 with significant implications for the mortgage marketplace. Of the two final rules from the Bureau, one drastically simplifies...more
The Consumer Financial Protection Bureau (CFPB) recently issued a proposed rule to create a new category of Seasoned Qualified Mortgages (QMs). The proposal seeks to “encourage safe and responsible innovation in the mortgage...more
The Consumer Financial Protection Bureau (CFPB or Bureau) on October 20 issued a final rule to extend the government-sponsored enterprises patch (GSE Patch), i.e., the “temporary qualified mortgage” exemption within the...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
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
When the federal Consumer Financial Protection Bureau (“CFPB”) last summer issued its Advance Notice of Proposed Rule Making (“ANPR”) to revise the definition of a “Qualified Mortgage” (“QM”) under the Dodd-Frank Act’s...more
A&B ABstract: A recent letter from Consumer Financial Protection Bureau (“CFPB”) Director Kathleen Kraninger provides clues about the potential future of the so-called “QM Patch.”...more
The CFPB has published its Fall 2019 rulemaking agenda as part of the Fall 2019 Unified Agenda of Federal Regulatory and Deregulatory Actions, which is coordinated by the Office of Management and Budget....more
The U.S. Department of Treasury recently issued the long-awaited Housing Reform Plan, and among various topics the Plan addresses the temporary qualified mortgage under the Regulation Z ability-to-repay rule for loans that...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
The CFPB recently issued an advance notice of proposed rulemaking (ANPR) requesting comments on how to revise the qualified mortgage (QM) provisions of the Regulation Z ability to repay rule in view of the impending...more
The U.S. District Court for the Southern District of Ohio recently issued a landmark decision regarding the reasonableness of a bank’s reliance on Appendix Q regarding nonemployment-related consumer income validation for a...more