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 […]
QM
CFPB Issues “Seasoned Qualified Mortgage” Rule
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 […]
CFPB Issues Its Fall 2019 Rulemaking Agenda
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 […]
CFPB Rules Permit Qualified Mortgage “Cures”
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 […]