Loan originators, their advisors and service providers are moving rapidly to achieve compliance by January 10, 2014 with the Consumer Financial Protection Bureau’s (“Bureau’s”) new rule, which generally imposes an affirmative...more
Below is a link to A Strategic Guide to the ATR/QM Rules (Guide), Dechert LLP’s analysis for the American Bankers Association (ABA) of the Ability-to-Repay (ATR) and Qualified Mortgage (QM) rules adopted by the Consumer...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
4/16/2013
/ Ability-to-Repay ,
Consumer Financial Protection Bureau (CFPB) ,
Disparate Impact ,
Fair Lending ,
HUD ,
Lenders ,
Loans ,
Mortgages ,
Qualified Mortgage Rule ,
Safe Harbors ,
Underwriting
The U.S. Consumer Financial Protection Bureau (the “Bureau”) has released a proposal (the "Proposal") to amend the Bureau's recently issued final rules (the “Rules”) on the definition of a qualified mortgage (“QM”) and the...more
Congress in the Dodd-Frank Act responded to concerns about the quality of mortgage loans by establishing incentives for lenders to seek to ensure that borrowers had the ability to repay mortgage loans made to them. In...more
1/16/2013
/ Ability-to-Repay ,
Borrowers ,
Consumer Financial Protection Bureau (CFPB) ,
Damages ,
Dodd-Frank ,
Foreclosure ,
Lenders ,
Loans ,
Mortgages ,
Penalties ,
Qualified Mortgage Rule ,
Rebuttable Presumptions ,
Safe Harbors ,
Truth in Lending Act (TILA)