Effective December 24, 2015, all securitizations of residential mortgage loans (RMBS), both public and private, will be subject to the Credit Risk Retention Rule (the “Rule”).[1] The Rule was promulgated on December 24, 2014,...more
The CFPB’s final rule amending certain provisions of the 2013 Title XIV final mortgage rules which includes a post-consummation points and fees cure mechanism for qualified mortgage loans, became effective on Monday, November...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
The Department of Housing and Urban Development issued a final rule defining a “qualified mortgage” for single family residential loans that it insures, guarantees or administers. The rule retains the definition of “qualified...more
Largely piggybacking off of the CFPB’s definition of qualified mortgage finalized in January 2013, HUD issued a proposed rule defining qualified mortgages. The rule requires a loan to have regular periodic payments (i.e., no...more
The new Risk Retention Rule published jointly by the FDIC, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System and the Securities Exchange Commission, with a little help from...more
On September 30, HUD issued a proposed rule that would define a Qualified Mortgage (QM) that would be insured, guaranteed or administered by HUD, including single-family forward mortgages insured by FHA. In order to meet...more
This week, the United States Department of Housing and Urban Development (“HUD”) weighed in on its proposed version of a Federal Housing Administration (“FHA”) Qualified Mortgage (“QM”). Although the Consumer Financial...more
As anticipated, HUD recently issued its proposed rule defining a qualified mortgage (QM) for HUD insured and guaranteed single family mortgages. Under the proposed rule, published in the Federal Register on Monday, Title II...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
On June 4, eight industry groups sent a letter addressed to HUD Secretary Shaun Donovan and CFPB Director Richard Cordray requesting much needed written guidance from HUD and the CFPB that makes clear that compliance with the...more
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
February has certainly been a big month for federal agencies to issue long-awaited final rules. The latest agency to throw its hat into the ring is the U.S. Department of Housing and Urban Development, which recently codified...more