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Truth in Lending Act (TILA) Ability-to-Repay Consumer Lenders

Ballard Spahr LLP

CFPB publishes annual CARD Act, HOEPA, QM adjustments

Ballard Spahr LLP on

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

Ballard Spahr LLP

Guidance from the OCC to banks regarding higher loan-to-value loan programs

Ballard Spahr LLP on

On August 21, 2017, the Office of the Comptroller of the Currency (OCC) published Bulletin 2017-28 regarding higher-loan-to-value (LTV) lending programs (the “Bulletin”). Recognizing the need for further revitalization...more

Morrison & Foerster LLP

Short-Term Lenders Face Costly Path To Compliance

On June 2, 2016, the Consumer Financial Protection Bureau released its long-anticipated notice of proposed rulemaking on short-term consumer lending. The proposed rule follows the CFPB’s March 2015 release of an outline of...more

Williams Mullen

First Round of ATR Cases Goes to Banks

Williams Mullen on

The CFPB’s ability-to-repay (ATR) rule became effective in January 2014. It requires mortgage lenders to determine during underwriting that a borrower has a reasonable ability to repay a loan according to its terms. ...more

Ballard Spahr LLP

CFPB issues final rule expanding definition of “small creditor” and “rural areas” under TILA

Ballard Spahr LLP on

The CFPB has issued a final rule that revises the definitions of “small creditor” and “rural areas” under Regulation Z of the Truth in Lending Act (TILA). The final rule is effective January 1, 2016. We previously reported on...more

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