A&B ABstract: A new rule from the federal banking regulators reduces the number of residential mortgage transactions for which an appraisal is required. The rule also incorporates changes to federal appraisal requirements made by the Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018. On September 27, 2019, the Federal Deposit Insurance Corporation, the […]
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CFPB Rules Permit Qualified Mortgage “Cures”
A&B Abstract: What happens when a proposed qualified mortgage is later discovered to have points and fees in excess of the statutory threshold? The answer lies in a cure provision scheduled to sunset on January 21, 2021. CFPB Rules Permit Qualified Mortgage “Cures” What happens to an originator or assignee of a “qualified mortgage” who […]
QM Patch Update: CFPB Proposes to Let Patch Expire
A&B Abstract The CFPB has issued an Advance Notice of Proposed Rulemaking regarding the fate of the “QM Patch,” indicating that it will not extend the “QM Patch” permanently. Advanced Notice of Proposed Rulemaking In a surprise development, on July 25, 2019, the Consumer Financial Protection Bureau (“CFPB”) issued an advance notice of proposed rulemaking […]
The Fate of the QM Patch
A&B Abstract: With the January 2021 expiration of the so-called “QM Patch” looming, what courses of action are available to the CFPB? Background One of the most vexing issues currently facing the Consumer Financial Protection Bureau (“CFPB”) is the fate of the so-called “QM Patch”. The CFPB’s ability-to-repay/qualified mortgage regulations promulgated pursuant to the Dodd-Frank […]