Below is a link to A Strategic Guide to the ATR/QM Rules (Guide), Dechert LLP’s analysis for the American Bankers Association (ABA) of the Ability-to-Repay (ATR) and Qualified Mortgage (QM) rules adopted by the Consumer...more
On May 29, 2013, the Consumer Financial Protection Bureau (CFPB) issued a final rule amending its Ability to Repay/Qualified Mortgage (ATR/QM) rule, originally issued on January 10, 2013....more
The CFPB has amended its Ability-to-Repay rule to facilitate access to credit by creating specific exemptions and modifications to the CFPB’s Ability-to-Repay rule for small creditors, community development lenders, and...more
In This Presentation: - The Qualified Mortgage (QM) Rule - Small Creditor QM Proposal - The Ability-to-Repay (ATR) Rule: What It Says and What It Means - Liability for Failure to Comply with the ATR and QM...more
On Thursday, January 10, 2013, the Consumer Financial Protection Bureau ("CFPB") issued a final rule amending Regulation Z pursuant to the Dodd-Frank Wall Street Reform and Consumer Protection Act (the "Dodd-Frank Act"). ...more
Rule lists criteria that lenders must consider in determining a prospective borrower has the ability to repay a loan and defines Dodd-Frank's concept of a "qualified mortgage." On January 10, the Consumer Financial...more
Congress in the Dodd-Frank Act responded to concerns about the quality of mortgage loans by establishing incentives for lenders to seek to ensure that borrowers had the ability to repay mortgage loans made to them. In...more
The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) amended the Truth in Lending Act (TILA) to provide for an expanded ability-to-repay requirement for the mortgage lending industry. The Consumer...more
The Consumer Financial Protection Bureau (CFPB) issued its final ability to repay rule (Rule) on January 10, 2013. The Rule implements ability-to-repay provisions of the Dodd-Frank Act, which imposed strict underwriting...more