Archive

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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ACTING CFPB DIRECTOR SETS PRIORITIES AND EXPLORES PRESERVING QM STATUS QUO

As expected, and as we discussed in our recent “Compliance Expectations for the New Administration” webinar, the Biden administration is effecting changes in financial oversight that will impact financial institutions. One of those changes included, at the request of President Biden, was the resignation of CFPB Director Kathy Kraninger and the appointment of Dave Uejio as Acting Director of the CFPB; Acting Director Uejio will serve until President Biden’s nominee for CFPB Director, Rohit Chopra, […]

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ATR/QM POLL

Recently we polled our Compliance Master Group members on the Ability-to-Repay/Qualified Mortgages rules. There were no huge surprises, but we got a lot of confirmation of what we expected to see: Most creditors use a mix of ATR/QM options; The Small Creditor QM is the most popular ATR/QM option; Adopting the ATR/QM rules was a challenge, but did not reduce loan volume for most creditors; and Most creditors have not yet adopted Appendix Q, but […]

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NEW RISK RETENTION (QRM) PROPOSAL

On August 28 the Board of Governors of the Federal Reserve System, the Department of Housing and Urban Development, the Federal Deposit Insurance Corporation, the Federal Housing Finance Agency, the Office of the Comptroller of the Currency, and the Securities and Exchange Commission issued a notice revising a proposed rule requiring sponsors of securitization transactions to retain risk in those transactions. The new proposal revises a proposed rule the agencies issued in 2011 to implement […]

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CFPB PROPOSES MORE CHANGES TO THE QM AND SERVICING CHANGES

On April 19th the Consumer Financial Protection Bureau (CFPB) proposed changes to the Qualified Mortgage (QM) and Servicing Rules. The proposal addresses five topics: Debt-to-Income Ratio Under the Ability to Repay rule, a lender may make a qualified mortgage (QM), a loan for which certain features are prohibited and fees that can be charged are limited. The rule provides for different types of QMs, the main type requiring that a consumer’s debt-to-income ratio (DTI) show […]

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