News & Analysis as of

Federal Reserve Ability-to-Repay National Credit Union Administration

Ballard Spahr LLP

Federal banking agencies and CFPB issue interagency statement on use of alternative data in credit underwriting

Ballard Spahr LLP on

The OCC, Federal Reserve Board, FDIC, NCUA and CFPB have issued an “Interagency Statement on the Use of Alternative Data in Credit Underwriting.”...more

Ballard Spahr LLP

Prudential Regulators Clarify Supervisory Approach Relative to CFPB Mortgage Regulation

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The Federal Deposit Insurance Corporation, the Board of Governors of the Federal Reserve System, the National Credit Union Administration, and the Office of the Comptroller of the Currency (the “Prudential Regulators”) have...more

Orrick - Finance 20/20

Supervisory Approach for Qualified and non-Qualified Mortgage Loans

Orrick - Finance 20/20 on

On December 13, Fed, FDIC, NCUA and OCC issued a statement to clarify safety-and-soundness expectations in order to guide institutions engaged in residential mortgage lending as they assess the implementation of the CFPB’s...more

Goodwin

Federal Regulators Issue Statement on Fair Lending Compliance and the Ability-to-Repay and Qualified Mortgage Rules

Goodwin on

In response to inquiries from creditors about liability under the Equal Credit Opportunity Act’s disparate impact doctrine on originating qualified mortgages under the CFPB’s ability-to-repay provisions, the CFPB, OCC, FRB,...more

Morrison & Foerster LLP

Interagency Fair Lending Guidance: A First Step, but in the Right Direction?

Morrison & Foerster LLP on

Five federal regulators, with HUD noticeably absent, issued the first interagency guidance on the much-debated intersection of fair lending enforcement and the Ability-to-Repay and Qualified Mortgage Standards Rule taking...more

Ballard Spahr LLP

CFPB joins interagency statement on qualified mortgage fair lending risks

Ballard Spahr LLP on

The CFPB was one of five federal regulators issuing an interagency statement intended to address industry concerns regarding the fair lending risks associated with compliance with the CFPB’s ability-to-repay/qualified...more

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