News & Analysis as of

Ability-to-Repay Truth in Lending Act (TILA) Regulation Z

Perkins Coie

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

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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

Perkins Coie

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

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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

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

Troutman Pepper

Federal Court Clarifies Banks' Obligations Under Appendix Q

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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

Ballard Spahr LLP

CFPB publishes annual CARD Act, HOEPA, QM adjustments

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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

Ballard Spahr LLP

CFPB publishes annual CARD Act, HOEPA, QM adjustments

Ballard Spahr LLP on

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

Kilpatrick

CFPB Issues Long-Awaited Prepaid Account Products Final Rule

Kilpatrick on

On October 5, 2016, the Consumer Financial Protection Bureau (the Bureau or the CFPB) issued its final rule to extend certain federal consumer protections to the prepaid market.1 Specifically, the rule extends Regulation E...more

Ballard Spahr LLP

CFPB publishes annual CARD Act, HOEPA and QM adjustments, corrects 2016 error

Ballard Spahr LLP on

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

Ballard Spahr LLP

CFPB Issues Second Rule to Implement the HELP Act, Expanding Qualified Mortgage Coverage for Lenders in Rural and Underserved...

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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

Ballard Spahr LLP

CFPB issues second rule to implement the HELP Act, expanding Qualified Mortgage coverage for lenders lending in rural and...

Ballard Spahr LLP on

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

Ballard Spahr LLP

CFPB issues final rule expanding definition of “small creditor” and “rural areas” under TILA

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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

Ballard Spahr LLP

CFPB Provides Guidance on Ability-To-Repay Rule Application to Assumptions of Residential Mortgage Loans

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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

Perkins Coie

Financial Services Bulletin: Action At The CFPB, SEC, And CFTC

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The CFPB Amends Ability-to-Repay and Qualified Mortgage Standards - On Wednesday, May 29, 2013, the Consumer Financial Protection Bureau (the “CFPB”) issued amendments to Regulation Z, which implements the Truth in Lending...more

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