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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: Consumer Financial Protection Bureau (CFPB), Mortgage Loans Tagged With: #seasonedQM, QM

CFPB Issues “Seasoned Qualified Mortgage” Rule

January 4, 2021 By Stephen Ornstein

  A&B ABstract:  On December 10, 2020, the Consumer Financial Protection Bureau (CFPB) issued an innovative final rulemaking that creates a pathway to “safe harbor” Qualified Mortgage (QM) status for performing non-QM and “rebuttable presumption” QM loans that meet certain performance criteria portfolio requirements over a seasoning period of at least 36 months and that […]

Filed Under: Consumer Financial Protection Bureau (CFPB), Mortgage Loans Tagged With: #QualifiedMortgage, QM

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

CFPB Rules Permit Qualified Mortgage “Cures”

September 23, 2019 By Stephen Ornstein

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 […]

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

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Recent Posts

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