News & Analysis as of

Ability-to-Repay Proposed Rules

Perkins Coie

The CFPB Proposes to Create a New Category of Seasoned Qualified Mortgages

Perkins Coie on

The Consumer Financial Protection Bureau (CFPB) recently issued a proposed rule to create a new category of Seasoned Qualified Mortgages (QMs). The proposal seeks to “encourage safe and responsible innovation in the mortgage...more

Goodwin

CFPB Proposes New “Seasoned” Qualified Mortgage Category

Goodwin on

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

Buchalter

CFPB Issues Proposed Rule to Create New Category of “Seasoned Qualified Mortgages”

Buchalter on

On August, 18, 2020, the CFPB issued a new proposed rule to create a new category of “seasoned qualified mortgages” (Seasoned QMs) that would receive the safe harbor conclusive presumption of meeting the Ability to Repay...more

Ballard Spahr LLP

CFPB Seeks Comment on Proposed Rules Addressing "Unique Nature" of PACE Financing

Ballard Spahr LLP on

The Consumer Financial Protection Bureau (CFPB) has opened the public comment phase on its proposed rules on regulation of Property Assessed Clean Energy (PACE) loans for upfront costs of eligible energy improvements....more

Ballard Spahr LLP

CFPB proposes revisions to final payday/auto title/high-rate installment loan rule

Ballard Spahr LLP on

The CFPB has issued highly-anticipated proposed revisions to its final payday/auto title/high-rate installment loan rule (Rule) that would rescind the Rule’s ability-to-repay provisions in their entirety (which the CFPB...more

Orrick - Finance 20/20

Public Statement Regarding Payday Rule Reconsideration and Delay of Compliance Date

Orrick - Finance 20/20 on

On October 26, the Consumer Financial Protection Bureau (the “Bureau“) issued a statement announcing that it expects to issue proposed rules in January 2019 that will reconsider the Bureau’s rule regarding Payday, Vehicle...more

Bradley Arant Boult Cummings LLP

CFPB Issues Final Rules on Payday and Vehicle Title Loans—Little Impact for Auto Lenders

The Consumer Financial Protection Bureau (CFPB) issued its final rule on payday, vehicle title, and certain high-cost installment loans. The new rule is effective in 2019 and imposes stringent underwriting requirements and...more

Morrison & Foerster LLP

A Closer Look at the CFPB’s Proposed Short-Term Lending Rule

As we previously reported in our June 3, 2016 client alert, the Consumer Financial Protection Bureau (“CFPB”) has issued a Notice of Proposed Rulemaking for short-term loans (“Proposed Rule”). In this follow-up alert, we take...more

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