Archive

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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CFPB ISSUES TWO QM RULES

On December 10, 2020, the Consumer Financial Protection Bureau (CFPB) issued two final rules related to qualified mortgage (QM) loans. The first final rule, the General QM Rule, replaces the current requirement for General QM loans that the consumer’s debt-to-income ratio (DTI) not exceed 43 percent with a limit based on the loan’s pricing. The second final rule, reveals a new Seasoned QM. General QM – Under the final rule a loan receives a conclusive […]

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CFPB ADVISORY OPINIONS

On November 30, 2020, the Consumer Financial Protection Bureau (CFPB) issued its Advisory Opinions Policy, which sets forth procedures to facilitate the submission by interested parties of requests that the CFPB issue advisory opinions, in the form of interpretive rules, to resolve regulatory uncertainty, and the manner in which the Bureau will evaluate and respond to such requests. The CFPB also released its first Advisory Opinions that clarify the following Regulation Z issues: Private Education […]

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