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PROPOSED TIL CHANGES – GOOD NEWS?

On April 30 the Consumer Financial Protection Bureau (CFPB) proposed changes to Regulation Z rules related to the small servicer exemption and to the qualified mortgage rules. The proposal is on a fast track, with a 30-day comment period. Small Servicer The proposed changes to the small servicer rules are nice. The CFPB proposes an alternative small servicer definition for nonprofit entities that meet certain requirements, and amend the existing exemption from the ability-to-repay rule […]

CFPB ABILITY TO REPAY AND QM GUIDANCE

On April 10, 2013 the Consumer Financial Protection Bureau published two compliance tools to assist financial institutions with implementation of the ability to repay and the qualified mortgage rules. The first tool is a 45-page booklet entitled Ability-to-Repay and Qualified Mortgage Rule – Small Entity Compliance Guide. The Guide is available here. The second tool is a 1½ page chart entitled General Comparison of Ability-to-Repay Requirements with Qualified Mortgages. The chart is available here.