Episode 25: 10 Factors That May Hinder a Contractor’s Ability to Repay Its Bank Loans and Threaten Its Existence
Critical Mortgage Regulatory Updates by the Consumer Financial Protection Bureau for 2013 and 2014
As previously reported, the CFPB proposed to delay the mandatory compliance date for the new general qualified mortgage (QM) rule that amends the Regulation Z ability to repay/QM rule from July 1, 2021 to October 1, 2022....more
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
In anticipation of the “GSE patch” expiring, the Consumer Financial Protection Bureau (“CFPB”) issued several final rules in 2020 to amend Regulation Z (“Reg. Z”). Concerns have existed that the expiration of the GSE patch...more
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
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
The CFPB recently issued a final rule that amends the Regulation Z ability to repay/qualified mortgage rule by extending the sunset date for the qualified mortgage (QM) based on a loan meeting certain product requirements and...more
On August 18, 2020, the Consumer Financial Protection Bureau (CFPB) issued a proposed rule to create a new category of loans known as “seasoned” qualified mortgages (Seasoned QMs). This new category of qualified mortgages...more
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
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
The U.S. District Court for the Southern District of Ohio recently issued a landmark decision regarding the reasonableness of a bank’s reliance on Appendix Q regarding nonemployment-related consumer income validation for a...more
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
On May 4 H.R. 10, the Financial CHOICE Act (the Act) introduced by House Financial Services Committee Chairman Jeb Hensarling, R-Texas, obtained enough votes to move the bill on to the House of Representatives floor. The Act...more
The CFPB’s newly-released Spring 2017 edition of Supervisory Highlights covers supervisory activities generally completed between September and December 2016. The report indicates that supervisory resolutions resulted in...more
In its Fall 2016 Supervisory Highlights, which covers supervision work generally completed between May and August 2016, the CFPB highlights violations found by its examiners involving origination and servicing of auto...more
As we have addressed, Congress passed the Helping Expand Lending Practices in Rural Communities Act of 2015 (HELP Act) on December 4, 2015, in efforts to expand the designation of additional areas as being "rural" under...more
As we have addressed, Congress passed the Helping Expand Lending Practices in Rural Communities Act of 2015 (HELP Act) on December 4, 2015, in efforts to expand the designation of additional areas as being “rural” under...more
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
The CFPB recently provided guidance on the application of the Regulation Z ability-to-repay rule (Section 1026.43) to assumptions of residential mortgage loans for purposes of clarifying the application of the rule in cases...more
On January 10, 2013, the Consumer Financial Protection Bureau issued much-anticipated revisions to Regulation Z to implement provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act that require lenders to...more
The Consumer Financial Protection Bureau (CFPB) began the new year by continuing to refine Regulation Z, which implements the Truth in Lending Act, and Regulation X, which implements the Real Estate Settlement Procedures Act....more