News & Analysis as of

Financial Regulatory Reform Ability-to-Repay

Troutman Pepper

South Carolina Proposes Legislation to Impose Ability-to-Repay Analysis for Installment and Payday Loans

Troutman Pepper on

On January 9, a group of five bi-partisan South Carolina Senators introduced Bill 910, which would, among other things, require persons (non-bank lenders) providing “consumer installment loans” or “deferred presentment loans”...more

Morgan Lewis - All Things FinReg

CFPB Finalizes Delay of Mandatory Compliance Date for General Qualified Mortgage Final Rule

On April 27, 2021, the Consumer Financial Protection Bureau (CFPB or Bureau) issued a final rule formally delaying the mandatory compliance date for the rule defining a “qualified mortgage” (QM) (the General QM Final Rule)...more

Morgan Lewis - All Things FinReg

CFPB Provides Status Update Concerning Recently Finalized Qualified Mortgage Rules

We previously reported on recent mortgage rulemakings that were finalized by the Consumer Financial Protection Bureau (CFPB or Bureau) late last year. Of the two final rules from the Bureau, one drastically simplifies the...more

Dechert LLP

CFPB Issues Two Final Rules: A Change to the General Qualified Mortgage Rule and the Seasoned Qualified Mortgage Rule

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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

Mayer Brown

CFPB Issues New QM Definition and Seasoning Provisions

Mayer Brown on

The Consumer Financial Protection Bureau (“CFPB”) issued two relatively welcome surprises yesterday. First, along with ditching a debt-to-income ratio (“DTI”) ceiling, the agency expanded its proposed general Qualified...more

Morgan Lewis

CFPB Finalizes Qualified Mortgage Changes

Morgan Lewis on

The Consumer Financial Protection Bureau (Bureau or CFPB) issued two final rules on December 10 with significant implications for the mortgage marketplace. Of the two final rules from the Bureau, one drastically simplifies...more

Morgan Lewis - All Things FinReg

CFPB Issues Final Rule Extending the Qualified Mortgage ‘GSE Patch’

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

Morgan Lewis

CFPB Proposes New ‘Seasoned’ Qualified Mortgage Category

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The Consumer Financial Protection Bureau (CFPB or Bureau) issued a proposed rule on August 18 to create a new category of seasoned qualified mortgages (Seasoned QMs) that, if finalized as written, would carry significant...more

Morgan Lewis

CFPB Proposes Substantial Amendments to Qualified Mortgage Definition, Addresses GSE Patch

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The Consumer Financial Protection Bureau on June 22 issued two proposed rules with significant implications for the mortgage marketplace....more

Mayer Brown

Revising the Regulatory Definition of a Qualified Mortgage

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When the federal Consumer Financial Protection Bureau (“CFPB”) last summer issued its Advance Notice of Proposed Rule Making (“ANPR”) to revise the definition of a “Qualified Mortgage” (“QM”) under the Dodd-Frank Act’s...more

Ballard Spahr LLP

House Financial Services Committee: “rent-a-bank” hearing on Feb. 5; Director Kraninger to testify on Feb. 6

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On Wednesday, February 5, the House Financial Services Committee will hold the first part of a two-part hearing on “rent-a-bank” structures. The hearing is titled “Rent-A-Bank Schemes and New Debt Traps: Assessing Efforts to...more

Ballard Spahr LLP

Treasury Housing Reform Plan Supports Expiration of GSE Patch for Qualified Mortgages

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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

Bilzin Sumberg

CFPB Decision on “GSE Patch” Revives Debate About Prudent Underwriting

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The Consumer Financial Protection Bureau (CFPB) recently announced that it will allow the so-called “GSE patch” to expire in January 2021. This patch permits Government-Sponsored Entities Fannie Mae and Freddie Mac to buy...more

Ballard Spahr LLP

CFPB publishes Spring 2019 rulemaking agenda

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The CFPB has published its Spring 2019 rulemaking agenda as part of the Spring 2019 Unified Agenda of Federal Regulatory and Deregulatory Actions, which is coordinated by the Office of Management and Budget (OMB).  ...more

Ballard Spahr LLP

CFPB issues small entity compliance guide for payday loan rule payment provisions

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The CFPB has issued a new small entity compliance guide: “Payday, Vehicle Title and High-Cost Installment Lending Rule: Payment-Related Provisions.”...more

Bricker Graydon LLP

Qualified mortgages: The uncertain future of the GSE patch

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Late last month, President Trump’s administration released a wide-sweeping reform and reorganization plan for the federal government. Included in this plan was a proposal to reform two of the largest government sponsored...more

Mintz - Public Finance Viewpoints

Financial Services Legislative and Regulatory Update -- January 13, 2014

In This Issue: Leading the Past Week; Executive Branch; International; and Upcoming Hearings. Excerpt from Leading the Past Week - Last week closed with the long anticipated ability-to-repay and...more

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