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QM

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

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: Ability to Repay/Qualified Mortgage, 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

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