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A&B ABstract: Three recent actions by the Consumer Financial Protection Bureau (“CFPB”), on consecutive days, highlights inconsistencies in the CFPB’s current approach to payday lending....more
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
The Treasury Department recently issued a request for information to explore various aspects of “online marketplace lending.” The RFI seeks comment on a broad array of online financial services companies that lend not only to...more
Last Thursday, the Office of the Comptroller of the Currency and Federal Deposit Insurance Corporation proposed guidance on deposit advance loans. The Federal Reserve Board declined to join the OCC and FDIC and instead...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
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
On January 10, the Consumer Financial Protection Bureau (CFPB) issued a final rule, as mandated by provisions of the Dodd-Frank Wall Street Reform and Consumer Protection Act (DFA), which requires mortgage lenders to consider...more
The CFPB has issued its long-awaited ability to repay/qualified mortgage rule, and at first glance, it appears to warrant cautious optimism for the mortgage industry....more