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Stephen Ornstein

Juneteenth Holiday Raises Tricky TRID Disclosure Issues

June 18, 2021 By Stephen Ornstein

On June 17, 2021, President Biden signed legislation making Juneteenth National Independence Day a federal national holiday. The first observance of the holiday is Friday, June 18, 2021. While the enactment of this new federal holiday is a notable and welcome national event, its first observance has immediate consequences for the timing of certain disclosures […]

Filed Under: Mortgage Loans, TRID Tagged With: #Juneteenth

The QM Patch Is Down for the Count

June 9, 2021 By Stephen Ornstein

Whether they realize it or not, absent a last-minute intervention from the Federal Housing Finance Agency (FHFA), effective July 1, 2021, creditors will no longer be able to originate qualified mortgage loans using the “QM Patch.” The reason for this dramatic event is that on April 8, 2021, Fannie Mae and Freddie Mac announced in separate […]

Filed Under: Ability to Repay/Qualified Mortgage, Consumer Financial Protection Bureau (CFPB), Federal Housing Finance Agency (FHFA) Tagged With: #QMPatch, QM

Fannie Mae and Freddie Mac Sunset the QM Patch

April 13, 2021 By Stephen Ornstein

The qualified mortgage (QM) rules have become a world of contradictions. In a client advisory, our Financial Services & Products Group investigates how the residential mortgage markets can thread the needle between new rulings from Fannie Mae and Freddie Mac and recent rulings from the Consumer Financial Protection Bureau.

Filed Under: Ability to Repay/Qualified Mortgage, Uncategorized Tagged With: #FannieMae, #FreddieMac, #QMPatch, QM

CFPB Delays Implementation of General “QM” Rule, May Jettison the “Seasoned QM” Rule

February 25, 2021 By Stephen Ornstein

A&B ABstract In a statement issued on February 23, 2021, the Consumer Financial Protection Bureau (“CFPB”) indicated that it intends to delay the General Qualified Mortgage (“QM”) rule’s mandatory July 1 2021 compliance date, and may amend or revoke the “Seasoned QM Rule” that was supposed to become effective on March 1, 2021. Background As […]

Filed Under: Ability to Repay/Qualified Mortgage, Consumer Financial Protection Bureau (CFPB), Mortgage Loans Tagged With: #seasonedQM, QM

New York State Revises Restrictive HECM Foreclosure Law

February 11, 2021 By Stephen Ornstein

A&B ABstract On December 15, 2020, New York State enacted legislation amending the New York Real Property Law that would have placed various restrictions and requirements on the servicing of Home Equity Conversion Mortgages secured by New York properties effective as of April 14, 2021 (the “Foreclosure Law”).  The new law would significantly hinder a […]

Filed Under: Mortgage Loans, State Law Tagged With: #HECM

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