News & Analysis as of

Ability-to-Repay Public Comment

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

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

Alston & Bird

QM Patch Update: CFPB Proposes to Let Patch Expire

Alston & Bird on

A&B Abstract - The CFPB has issued an Advance Notice of Proposed Rulemaking regarding the fate of the “QM Patch,” indicating that it will not extend the “QM Patch” permanently....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

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