Archive

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 […]

NEW RISK RETENTION (QRM) PROPOSAL

On August 28 the Board of Governors of the Federal Reserve System, the Department of Housing and Urban Development, the Federal Deposit Insurance Corporation, the Federal Housing Finance Agency, the Office of the Comptroller of the Currency, and the Securities and Exchange Commission issued a notice revising a proposed rule requiring sponsors of securitization transactions to retain risk in those transactions. The new proposal revises a proposed rule the agencies issued in 2011 to implement […]

CFPB PUBLISHES THE FINAL FINAL ABILITY-TO-REPAY AND QUALIFIED MORTGAGE STANDARDS

On May 29, 2013 the Consumer Financial Protection Bureau (CFPB) published a final2 rule to amend a final rule published in January 2013 that generally prohibits a creditor from making a mortgage loan unless the creditor determines that the consumer will have the ability to repay the loan.. The final2 rule provides an exemption to these requirements for creditors with certain designations, loans pursuant to certain programs, certain nonprofit creditors, and mortgage loans made in connection […]

CFPB PUBLISHES FINAL LIST OF RURAL AND UNDERSERVED COUNTIES

Recently the Consumer Financial Protection Bureau (CFPB) published the final list of counties designated as rural or underserved.  This final list is identical to the preliminary list published on March 12. The list is used to determine if escrows are required for certain higher-priced mortgage loans. Escrow rules for higher-priced mortgage loans (HPMLs) are scheduled to go into effect  on June 1, 2013. The rules require creditors to create and maintain escrow accounts for a […]

CFPB PROPOSES MORE CHANGES TO THE QM AND SERVICING CHANGES

On April 19th the Consumer Financial Protection Bureau (CFPB) proposed changes to the Qualified Mortgage (QM) and Servicing Rules. The proposal addresses five topics: Debt-to-Income Ratio Under the Ability to Repay rule, a lender may make a qualified mortgage (QM), a loan for which certain features are prohibited and fees that can be charged are limited. The rule provides for different types of QMs, the main type requiring that a consumer’s debt-to-income ratio (DTI) show […]