Archive

CFPB FINALIZES DELAY OF RECENT QM RULES

On April 27, 2021, the Consumer Financial Protection Bureau (CFPB) published a final rule extending the mandatory compliance date of the General Qualified Mortgage (QM) Final Rule from July 1, 2021 to October 1, 2022. Additionally, the April 2021 Final Rule affects the expiration of the Temporary GSE QM loan definition or “Patch.” Under the April 2021 Final Rule, the Temporary GSE QM loan definition will expire on October 1, 2022 or the date the […]

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CFPB PROPOSES DELAY OF REVISED GENERAL QM RULE

On March 3, 2021 the Consumer Financial Protection Bureau (CFPB) announced a notice of proposed rulemaking (NPRM) that would delay the mandatory compliance date of the General Qualified Mortgage (QM) final rule from July 1, 2021 to October 1, 2022. If the NPRM is finalized as proposed, the old, DTI-based General QM definition; the new, price-based General QM definition; and the GSE QM would all remain available as long as the lender received the consumer’s […]

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CFPB WAFFLING ON QUALIFIED MORTGAGE RULES

On February 23, 2021, Dave Uejio, acting director of the Consumer Financial Protection Bureau (CFPB), issued a statement that announced, “We expect to propose a rule to delay the General QM Final Rule’s July 1, 2021 mandatory compliance date. An extension of the compliance deadline would allow lenders more time in which they could make QM loans based on a debt-to-income ratio or whether the loans are eligible for sale to Fannie Mae or Freddie […]

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TRID AND DAYLIGHT SAVING TIME

Daylight Saving Time (DT) begins on Sunday March 14, 2021 at 2:00 a.m. It ends on November 7, 2021 at 2:00 a.m. What does DT have to do with TRID? The TRID rules under Regulation Z require creditors to disclose the time zone applicable to its location when disclosing the date and time the interest rate lock and estimate of closing costs will expire on the loan estimate. As a result, financial institutions located in […]

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CFPB ISSUES HPML ESCROW EXEMPTION

On January 19. 2021, the Consumer Financial Protection Bureau (CFPB) issued a final rule amending section 1026.35 of Regulation Z to implement a requirement of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA). The final rule exempts certain insured depository institutions and insured credit unions from the requirement to establish escrow accounts for certain higher-priced mortgage loans (HPMLs). The rule will take effect on publication in the Federal Register. It exempts from the HPML escrow […]

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