In this Issue. The Consumer Financial Protection Bureau (CFPB) issued a statement announcing its intention to revisit Trump-era qualified mortgage (QM) final rules; the Biden Administration announced changes to the Small...more
Effective December 24, 2015, all securitizations of residential mortgage loans (RMBS), both public and private, will be subject to the Credit Risk Retention Rule (the “Rule”).[1] The Rule was promulgated on December 24, 2014,...more
While Director Cordray’s appearance at the House Financial Services Committee’s hearing on the CFPB’s fifth Semi-Annual Report yesterday was accompanied by the usual dose of political theater, his testimony did yield the...more
The FDIC, OCC, NCUA and FRB issued an interagency statement on the supervisory approach to originating qualified mortgages under the CFPB’s ability-to-repay and qualified mortgage rule finalized in January 2013 and...more
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
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
Final Rules Implementing the Volcker Rule - On December 10, the Fed, CFTC, FDIC, OCC and SEC issued final rules to implement Section 619 of the Dodd-Frank Act (the Volcker Rule), which prohibit insured depository...more
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
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
On October 22, the Fed, CFPB, FDIC, NCUA and OCC issued a joint statement to address industry questions on fair lending risks associated with offering only qualified mortgages....more
Joint Release on QM Fair Lending Risks - On October 22, the Fed, CFPB, FDIC, NCUA and OCC issued a joint statement to address industry questions on fair lending risks associated with offering only qualified mortgages. ...more
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
Federal regulators have issued an interagency statement intended to address industry concerns regarding the fair lending risks associated with compliance with the Consumer Financial Protection Bureau’s...more
Collectively, the FDIC, the OCC, FRB, SEC, FHFA, and HUD issued a second proposal Notice of Proposed Rulemaking to implement the risk retention requirements of the Dodd-Frank Act. Section 941 of the Dodd-Frank Act amended...more
The Federal Reserve, FDIC, OCC, SEC, FHFA, and HUD will purportedly soon release for comment a new Qualified Residential Mortgage (QRM) Rule that may align with the Qualified Mortgage (QM) Rule so that the QRM exemption is...more
In This Issue: Financial Industry Developments: CFPB Proposed Clarifications on Qualified Mortgage Rules; SEC Credit Ratings Roundtable; FDIC Proposed Guidance on Deposit Advance Products; Rating Agency Developments; RMBS...more
In this issue: - CBOE Proposes to Amend Preferred Market Maker’s Continuous Quoting Obligations - FATCA Regulations Are Finalized - CFTC to Host Roundtable on “Futurization” of Swaps - CFTC Amends Order of...more
In This Issue: - Financial Industry Developments •CFPB Rules on Ability-to-Repay and Qualified Mortgages •Independent Foreclosure Review Settlement •CFPB Final Rules on High-Cost Mortgages •Rating Agency...more