On March 3, 2021 the Consumer Financial Protection Bureau (CFPB) announced a notice of proposed rulemaking (NPRM) that would delay the mandatory compliance date of the General Qualified Mortgage (QM) final rule from July 1, 2021 to October 1, 2022. If the NPRM is finalized as proposed, the old, DTI-based General QM definition; the new, price-based General QM definition; and the GSE QM would all remain available as long as the lender received the consumer’s […]
Tag: Truth in Lending
CFPB WAFFLING ON QUALIFIED MORTGAGE RULES
On February 23, 2021, Dave Uejio, acting director of the Consumer Financial Protection Bureau (CFPB), issued a statement that announced, “We expect to propose a rule to delay the General QM Final Rule’s July 1, 2021 mandatory compliance date. An extension of the compliance deadline would allow lenders more time in which they could make QM loans based on a debt-to-income ratio or whether the loans are eligible for sale to Fannie Mae or Freddie […]
CFPB ISSUES HPML ESCROW EXEMPTION
On January 19. 2021, the Consumer Financial Protection Bureau (CFPB) issued a final rule amending section 1026.35 of Regulation Z to implement a requirement of the Economic Growth, Regulatory Relief, and Consumer Protection Act (EGRRCPA). The final rule exempts certain insured depository institutions and insured credit unions from the requirement to establish escrow accounts for certain higher-priced mortgage loans (HPMLs). The rule will take effect on publication in the Federal Register. It exempts from the HPML escrow […]
CFPB ADVISORY OPINIONS
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 […]
CFPB PUBLISHES NPRM ON SEASONED QM LOAN
On August 18, 2020, the Consumer Financial Protection Bureau (CFPB) published a notice of proposed rulemaking (NPRM) that creates a new category of Qualified Mortgage (QM), a seasoned QM (Seasoned QM), for first-lien, fixed-rate covered transactions that have met certain performance requirements over a 36-month seasoning period, are held in portfolio until the end of the seasoning period, comply with general restrictions on product features and points and fees, and meet certain underwriting requirements. The […]