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On December 10, 2020, the Consumer Financial Protection Bureau (CFPB) issued two final rules related to qualified mortgage (QM) loans. The first final rule, the General QM Rule, replaces the current requirement for General QM loans that the consumer’s debt-to-income ratio (DTI) not exceed 43 percent with a limit based on the loan’s pricing. The second final rule, reveals a new Seasoned QM. General QM – Under the final rule a loan receives a conclusive

On November 30, 2020, the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, and the Federal Deposit Insurance Corporation (collectively, the agencies) issued a statement to encourage banks to cease entering into new contracts that use USD LIBOR as a reference rate as soon as practicable and in any event by December 31, 2021, in order to facilitate an orderly—and safe and sound— LIBOR transition.

On November 30, 2020, the Consumer Financial Protection Bureau (CFPB) issued its Advisory Opinions Policy, which sets forth procedures to facilitate the submission by interested parties of requests that the CFPB issue advisory opinions, in the form of interpretive rules, to resolve regulatory uncertainty, and the manner in which the Bureau will evaluate and respond to such requests. The CFPB also released its first Advisory Opinions that clarify the following Regulation Z issues: Private Education

On November 20, 2020, the Office of the Comptroller of the Currency (OCC) issued a Notice of Proposed Rulemaking (NPRM) that ensures that larger national banks and Federal savings associations offer and provide fair access to financial services. This is a most unusual proposal What The NPRM: Is a response to campaigns by political advocates who seek to achieve policy objectives by pressuring banks to stop providing financial services to customers (engaged in a lawful

On November 24, 2020, the Office of the Comptroller of the Currency (OCC) published a Notice of Proposed Rulemaking (NPRM) regarding the Community Reinvestment Act’s (CRA) general performance standards. The OCC published a final rule on May 20, 2020, with an October 1, 2020 effective date, to strengthen and modernize the agency’s regulations under the CRA to encourage banks to engage in more activities to serve the needs of their communities, particularly low- and moderate-income and other