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QM Patch

CFPB Issues Its Fall 2019 Rulemaking Agenda

November 27, 2019 By Nanci Weissgold and Anoush Garakani

A&B Abstract: On November 20, 2019, the Consumer Financial Protection Bureau (the “Bureau” or “CFPB”) published its Fall 2019 Rulemaking Agenda (the “Rulemaking Agenda”) as part of the Fall 2019 Unified Agenda of Federal Regulatory and Deregulatory Actions. The Rulemaking Agenda sets forth the matters that the Bureau reasonably anticipates having under consideration during the […]

Filed Under: Consumer Financial Protection Bureau (CFPB), Consumer Loan, Debt Collection, Dodd-Frank Act, Equal Credit Opportunity Act (ECOA), Fair Debt Collection Practices Act (FDCPA), Home Mortgage Disclosure Act (HMDA), Mortgage Loans, Real Estate Settlement Procedures Act (RESPA), TRID, Truth in Lending Act (TILA) Tagged With: #CFPB, #debtcollection, #FDCPA, Ability to Repay, Debt Collection, QM, QM Patch

QM Patch Update: CFPB Proposes to Let Patch Expire

August 4, 2019 By Stephen Ornstein

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 […]

Filed Under: Ability to Repay/Qualified Mortgage, Consumer Financial Protection Bureau (CFPB), Dodd-Frank Act, Mortgage Loans Tagged With: QM Patch, QM/ATR

The Fate of the QM Patch

July 22, 2019 By Stephen Ornstein

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 […]

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

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#California #CCPA #CFPA #CFPB #COVID=19 #debtcollection #FCRA #FDCPA #GSEs #Massachusetts #mortgageservicing #New York #NYDFS #Part419 #Privacy #QMPatch #redlining #validwhenmade abusive ATR/QM CARES Act Case law Connecticut Covid-19 CSBS Cybersecurity data breach Debt Collection DOJ Eleventh Circuit Fair Lending fintech Forbearance Foreclosure HUD licensing mortgage lending Mortgage Servicing passive investors QM QM Patch Regulation F Servicing student loan servicing UDAAP

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