Archive

IMMEDIATE IMPACT OF THE JUNETEENTH BILL

On June 17, 2021, President Biden signed a bill that creates the Juneteenth National Independence Day. The bill amends 5 U.S.C. 6103(a) to add “Juneteenth National Independence Day, June 19” as a specified legal public holiday.  This action impacts the definition of “business day,” as defined in Section 1026.2 of Regulation Z. Under TILA and Regulation Z, there are two definitions of “business day.”  The general rule definition is “a day on which the creditor’s […]

FIVE TRID FAQS ADDED

The Consumer Financial Protection Bureau has added five new questions and answers related to Housing Assistance Loans to the TILA-RESPA Integrated Disclosure FAQs. The new questions, which are effective immediately, cover: Are housing assistance loans covered by the TRID rule? What are the criteria for the Regulation Z Partial exemption from the Loan Estimate and Closing Disclosure Requirements? What are the criteria for the BUILD Act Partial Exemption from the Loan Estimate and Closing Disclosure […]

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 […]

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 […]

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 […]