News & Analysis as of

Ability-to-Repay GSE

Morgan Lewis - All Things FinReg

CFPB Provides Status Update Concerning Recently Finalized Qualified Mortgage Rules

We previously reported on recent mortgage rulemakings that were finalized by the Consumer Financial Protection Bureau (CFPB or Bureau) late last year. Of the two final rules from the Bureau, one drastically simplifies the...more

Dechert LLP

CFPB Issues Two Final Rules: A Change to the General Qualified Mortgage Rule and the Seasoned Qualified Mortgage Rule

Dechert LLP on

The Consumer Financial Protection Bureau (“CFPB”) recently issued two final rules aimed at bolstering the Qualified Mortgage (“QMs”) market. The first final rule amends the general eligibility category of QMs (“General QMs”)...more

Mayer Brown

CFPB Issues New QM Definition and Seasoning Provisions

Mayer Brown on

The Consumer Financial Protection Bureau (“CFPB”) issued two relatively welcome surprises yesterday. First, along with ditching a debt-to-income ratio (“DTI”) ceiling, the agency expanded its proposed general Qualified...more

Perkins Coie

The CFPB Proposes Amendments to the Qualified Mortgage Definition in Regulation Z and Extends the GSE Patch

Perkins Coie on

The Consumer Financial Protection Bureau (CFPB) recently proposed certain amendments to the General Qualified Mortgage (QM) definition in Regulation Z and issued a filing rule extending the expiration of the...more

Morgan Lewis - All Things FinReg

CFPB Issues Final Rule Extending the Qualified Mortgage ‘GSE Patch’

The Consumer Financial Protection Bureau (CFPB or Bureau) on October 20 issued a final rule to extend the government-sponsored enterprises patch (GSE Patch), i.e., the “temporary qualified mortgage” exemption within the...more

Morgan Lewis

CFPB Proposes New ‘Seasoned’ Qualified Mortgage Category

Morgan Lewis on

The Consumer Financial Protection Bureau (CFPB or Bureau) issued a proposed rule on August 18 to create a new category of seasoned qualified mortgages (Seasoned QMs) that, if finalized as written, would carry significant...more

Morgan Lewis

CFPB Proposes Substantial Amendments to Qualified Mortgage Definition, Addresses GSE Patch

Morgan Lewis on

The Consumer Financial Protection Bureau on June 22 issued two proposed rules with significant implications for the mortgage marketplace....more

Ballard Spahr LLP

CFPB Proposes Temporary Extension of the GSE Patch and Revised Approach to the General Qualified Mortgage

Ballard Spahr LLP on

The CFPB recently proposed a temporary extension of the qualified mortgage (QM) that is based on a loan being eligible for sale to Fannie Mae or Freddie Mac (often referred to as the “GSE Patch”). ...more

Mayer Brown

Self-Employed Borrower’s Income – Is the Past Necessarily Prologue?

Mayer Brown on

In a new era of double-digit unemployment resulting from the COVID-19 pandemic, it may be tough for a mortgage lender to predict the amount and stability of someone’s income in order to determine qualification for a home...more

Mayer Brown

Revising the Regulatory Definition of a Qualified Mortgage

Mayer Brown on

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

Ballard Spahr LLP

Treasury Housing Reform Plan Supports Expiration of GSE Patch for Qualified Mortgages

Ballard Spahr LLP on

The U.S. Department of Treasury recently issued the long-awaited Housing Reform Plan, and among various topics the Plan addresses the temporary qualified mortgage under the Regulation Z ability-to-repay rule for loans that...more

Bilzin Sumberg

CFPB Decision on “GSE Patch” Revives Debate About Prudent Underwriting

Bilzin Sumberg on

The Consumer Financial Protection Bureau (CFPB) recently announced that it will allow the so-called “GSE patch” to expire in January 2021. This patch permits Government-Sponsored Entities Fannie Mae and Freddie Mac to buy...more

Moore & Van Allen PLLC

CFPB’s ANPR Calls for the End of the GSE Patch

Moore & Van Allen PLLC on

Late last month the CFPB reignited debate when it issued an Advance Notice of Proposed Rulemaking (“ANPR”) stating its intention to allow the “GSE Patch” to expire in January 2021. The GSE Patch allows what would otherwise...more

Ballard Spahr LLP

CFPB Seeks Comment on Replacing Temporary GSE Patch Under Ability to Repay Rule

Ballard Spahr LLP on

The CFPB recently issued an advance notice of proposed rulemaking (ANPR) requesting comments on how to revise the qualified mortgage (QM) provisions of the Regulation Z ability to repay rule in view of the impending...more

Bricker Graydon LLP

Qualified mortgages: The uncertain future of the GSE patch

Bricker Graydon LLP on

Late last month, President Trump’s administration released a wide-sweeping reform and reorganization plan for the federal government. Included in this plan was a proposal to reform two of the largest government sponsored...more

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