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
Changes are coming in 2021 to the eligibility requirements for “Qualified Mortgage” or “QM” loans. The Ability-to-Repay/Qualified Mortgage Rule administered by CFPB (“ATR/QM Rule”) requires a creditor to make a reasonable,...more
Small Bank Holding Company and Qualified Mortgage Regulatory Relief Bills Pass House The U.S. House of Representatives has passed two regulatory relief bills with bipartisan support, one of which would raise the ceiling on...more
On May 12, 2015, U.S. Senator Richard Shelby (R-Ala.), Chairman of the United States Senate Committee on Banking, Housing, and Urban Affairs, released the text of draft legislation intended to reform the regulatory framework...more
Six federal agencies approved on October 22 a final rule requiring sponsors of securitization transactions to retain risk in those transactions. The final rule implements the risk retention requirements in the Dodd-Frank Wall...more
On October 22, 2014, six federal agencies adopted the final Credit Risk Retention Rule under Section 941 of the Dodd-Frank Act. The final rule will require sponsors of securitizations to retain an economic interest in the...more
Around 34% of all loan officers responding to a Fed survey indicated the CFPB’s Ability-to-Repay and Qualified Mortgage Standards under the Truth in Lending Act (the ATR/QM rule) makes it more difficult to get conforming...more
In This Issue: Leading the Past Week; Executive Branch; International; and Upcoming Hearings. Excerpt from Leading the Past Week - Last week closed with the long anticipated ability-to-repay and...more
Final Rules Implementing the Volcker Rule - On December 10, the Fed, CFTC, FDIC, OCC and SEC issued final rules to implement Section 619 of the Dodd-Frank Act (the Volcker Rule), which prohibit insured depository...more
Joint Proposal on Risk Retention - On August 28, the FDIC, Fed, FHFA, OCC, SEC and HUD issued a notice of revised proposed rulemaking relating to required risk retention by sponsors in securitization transactions. The...more
The Federal Reserve, FDIC, OCC, SEC, FHFA, and HUD will purportedly soon release for comment a new Qualified Residential Mortgage (QRM) Rule that may align with the Qualified Mortgage (QM) Rule so that the QRM exemption is...more
In This Issue: CFPB Final Rule Amendments to Ability to Repay and QM Rule; Extension of Loan Modification Programs; Freddie Mac $1 Billion Performing Modified Loan Securitization; FinCEN Guidance on Virtual Currency...more
On May 6, the FHFA announced that it is directing Fannie Mae and Freddie Mac to limit future mortgage acquisitions to loans that fall under the requirements for a qualified mortgage. Starting on January 10, 2014, Fannie and...more
In This Issue: FHFA Limit on Fannie and Freddie Loan Purchases to Qualified Mortgage; Rating Agency Developments; MBIA and Bank of America Settle MBS Litigation for $1.7 Billion: Assured and UBS Agree to Settle RMBS...more