Pursuant to section 1473(q) of the Dodd-Frank Act, a group of federal agencies have proposed a quality control rule for automated valuation models (AVMs). The agencies are the Comptroller of the Currency, Consumer Financial...more
Term SOFR emerges as the new market standard for aviation financing and leasing transactions. Market standards are evolving in new SOFR-based financings, including with respect to market disruption, breakage costs and...more
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
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
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
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
In the News. On the heels of a lawsuit challenging the Office of the Comptroller of the Currency’s (OCC) recently issued Madden fix/valid when made rule, eight state attorneys general filed suit challenging a similar rule...more
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
The Consumer Financial Protection Bureau on June 22 issued two proposed rules with significant implications for the mortgage marketplace....more
The CFPB recently proposed a temporary extension of the qualified mortgage (QM) that is based on a loan being eligible for sale to Fannie Mae or Freddie Mac (often referred to as the “GSE Patch”). ...more
As rumored, the Consumer Financial Protection Bureau (“CFPB”) is proposing to revise its general qualified mortgage definition by adopting a loan pricing test. Specifically, under the proposal, a residential mortgage loan...more
In a new era of double-digit unemployment resulting from the COVID-19 pandemic, it may be tough for a mortgage lender to predict the amount and stability of someone’s income in order to determine qualification for a home...more
What legislative activity can we expect in 2020 in the area of housing finance reform? With the Senate kicking off the New Year with an impeachment trial, it is highly unlikely Congress will make much headway on housing...more
The prospect of the U.S. Congress acting on housing reform this year remains unlikely. The House Democrats’ determination to formalize the impeachment inquiry into President Trump’s involvement with Ukraine and begin public...more
We continue to gauge the potential for Congress to act on the administration’s housing finance plan and/or pass their own before adjourning for the year. When Congress returned from August recess, members faced an ambitious...more
The U.S. Department of the Treasury and the Department of Housing released the much-anticipated housing finance reform plan to reduce the government’s role in housing and end government control of both Fannie Mae and Freddie...more
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
AARMR and CSBS are hosting a National Mortgage Policy Summit for policymakers, regulators, and the industry on November 13, 2019 in Washington, D.C. ...more
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
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
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
Now midway through the first session of the 116th Congress, the House and Senate have yet to act on housing reform legislation. Most recently, Mark Calabria, Director of the Federal Housing Finance Agency (FHFA), announced...more
Effective October 1, 2019, the Montana Mortgage Act is amended to include the following: Subject to certain exceptions: - For approved servicers by a government sponsored enterprise (GSE), a requirement that it...more
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