A&B ABstract: The CFPB must finalize its proposed QM delay rule in April, likely leaving no room for delay. Background on ATR/QM and the Delay Rule On March 3, 2021, the Bureau of Consumer Financial Protection (CFPB) released a notice of proposed rulemaking (NPRM) to delay the mandatory compliance date of the General Qualified Mortgage […]
ATR/QM
CFPB Director Provides Update Relating to QM Patch Expiration
A&B ABstract: A recent letter from Consumer Financial Protection Bureau (“CFPB”) Director Kathleen Kraninger provides clues about the potential future of the so-called “QM Patch.” Discussion: In a December 17, 2020 letter to Senator Mike Rounds (“Letter”), CFPB Director Kathleen Kraninger, revealed a number of interesting insights about the CFPB’s ongoing evaluation of the […]
Alston & Bird Issues Client Advisory on First-Known Decision Rendered by U.S. District Court, S. D. of Ohio (Eastern Division) Challenging CFPB’s ATR/QM Standards Favors Mortgage Industry
Alston & Bird Issues Client Advisory on First-Known Decision Rendered by U.S. District Court, S. D. of Ohio (Eastern Division) Challenging CFPB’s ATR/QM Standards Favors Mortgage Industry On April 24, 2019, Alston & Bird Partner Stephen Ornstein issued a Client Advisory to inform clients of an apparent case of first impression decided by the U.S. […]