News & Analysis as of

Threshold Requirements Loans

Ballard Spahr LLP

CFPB/Fed/OCC increase exemption thresholds for appraisal requirement, Regs Z and M (UPDATED)

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The CFPB, Fed, and OCC have announced that they are increasing three exemption thresholds that are subject to annual inflation adjustments.  Effective January 1, 2024 through December 31, 2024, these exemption thresholds are...more

Ballard Spahr LLP

Federal DC Court Overturns Closed-End Loan HMDA Reporting Threshold

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In April 2020, the CFPB issued a final HMDA rule increasing the Home Mortgage Disclosure Act (HMDA) reporting threshold for closed-end mortgage loans from 25 covered loans originated in each of the prior two years to 100...more

Mayer Brown

Revising the Regulatory Definition of a Qualified Mortgage

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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

Mayer Brown

CFPB on QM — No DTI? Short-Lived Patch Extension?

Mayer Brown on

According to the Mortgage Bankers Association, the Consumer Financial Protection Bureau intends to revise its Qualified Mortgage definition by moving away from a debt-to-income ratio threshold, and instead adopting a...more

Bradley Arant Boult Cummings LLP

NCUA’s Appraisal Threshold Increase to $1 Million for Commercial Real Estate Loans Set to Go into Effect

The National Credit Union Administration’s (NCUA) new appraisal threshold rule for commercial real estate loans will go into effect on October 22, 2019. Under the NCUA’s new appraisal rule, credit unions will not be required...more

Maynard Nexsen

NCUA Board Raises Commercial Real Estate Loan Appraisal Threshold to $1 Million

Maynard Nexsen on

The NCUA’s Board just approved a final rule “increasing the threshold below which appraisals are not required for commercial real estate transactions from $250,000 to $1,000,000.” This rule goes into effect October 22, 2019....more

Ballard Spahr LLP

House Financial Services Committee schedules Oct. 11 mark-up of “Madden fix” bill

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Among the more than 20 bills that the House Financial Services Committee is scheduled to mark-up this Wednesday, October 11, is a bill to provide a “Madden fix” as well as several others relevant to consumer financial...more

Morrison & Foerster LLP

CFPB, OCC, and Federal Reserve Propose Clarifications to Small Loan Exemption from HPML Appraisal Requirements

On August 4, 2016, the Consumer Financial Protection Bureau (“CFPB”), the Office of the Comptroller of the Currency (“OCC”), and the Board of Governors of the Federal Reserve System (“Federal Reserve”) (together, the...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

Agencies Issue Proposal on Method to Adjust Threshold for Exempting Small Loans from Special Appraisal Requirements - On July 22, 2016, the Consumer Financial Protection Bureau, the Federal Reserve Board and the Office...more

Polsinelli

SBA Proposes Updates to Business Loan Programs

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The Small Business Administration (SBA) on Tuesday published a proposed rule that would amend requirements in four of its business loan programs in order to increase participation among eligible entities. The agency announced...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week In Review

Agencies Issue Proposal on Method to Adjust Threshold for Exempting Small Loans from Special Appraisal Requirements - On July 22, 2016, the Consumer Financial Protection Bureau, the Federal Reserve Board and the Office...more

Ballard Spahr LLP

CFPB publishes annual CARD Act, HOEPA and QM adjustments

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The CFPB has 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

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