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
The CFPB has released a final list of “rural” or “underserved” counties for use in 2014. The CFPB has indicated that creditors may rely on this list as a safe harbor to determine whether a county is “rural” or “underserved”...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
Few would dispute that the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act or Act) has fundamentally altered the residential mortgage industry. Although the Act was passed just over three years ago,...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