TopMortgage Compliance Update (1)
 

January 10, 2013    

 


CFPB's Final Rule: Ability-to-Repay and Qualified Mortgages


Subscribe-Blue
Newsletter-Blue
 Website-Blue
 Forums-Blue
Twitter-2
Facebook-1
Linkedin-1
Banging Head Let us help!
Isn't it time to bring in the professionals? 
Contact Us-1-Beveled-160

Our Website Forums

LCG-Square-CC-2 (Blue)  

BCG-CC (134x134)  

CFPB Forum-CC-1  

OCC News Forum-CC-(134x134)  

BSA News Forum-Logo  

Mortgage Compliance Forum-Main  

Dodd-Frank Forum-CC-1  

NMLS Users Forum-CC-1  

FHA Forum-CC-1  

Veterans Mortgage Forum-Main  

516-442-3456  

Home-Website-LCG(160x27)-1
Compliance-Website-LCG(160x27)-1
Presentations-Website-LCG(160x27)-1
About Us-Website-LCG(160x27)-1
Clientele-Website-LCG(160x27)-1
Articles-Website-LCG(160x27)-1
Newsletters-Website-LCG(160x27)-1
Library-Website-LCG(160x27)-1
Contact Us-Website-LCG(160x27)-1
Greetings! 

Yesterday, I provided an outline of the Consumer Financial Protection Bureau's (CFPB's) Regulatory Agenda for 2013. As if on cue, the CFPB has accommodated us today with the first of its forthcoming issuances. This pertains to the Final Rule regarding Ability-to-Repay, which leaves the Final Rule issuances this month for Loan Originator Compensation, Mortgage Servicing, and Requirements for Escrow Accounts.

The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) required that, for residential mortgages, creditors must make a reasonable and good faith determination based on verified and documented information that the consumer has a reasonable ability to repay the loan according to its terms. It also established a "presumption" of compliance for a certain category of mortgages, which was called "qualified mortgages" or "QMs."

These provisions are similar, but not identical to, the Federal Reserve Board's (FRB's) 2008 rule and cover the entire mortgage market rather than simply higher-priced mortgages. The FRB proposed a rule to implement the new statutory requirements before authority passed to the CFPB to finalize the rule.

I have written extensively about Ability-to-Repay and the Qualified Mortgage. Please feel free to review these articles.

In this article, I would like to mention the premises used as the reasons for an Ability-to-Repay rule (ATR). Then I will outline the essential features of ATR, followed by a review of the "Qualified Mortgage." Finally, I will provide a general summation in order to provide some context with respect to  the Final Rule's implementation.

Best wishes!
Jonathan Foxx
President & Managing Director
Lenders Compliance Group
 Back
IN THIS ARTICLE

Premises for Ability-to-Repay
What is Ability-to-Repay?
What is the Qualified Mortgage?
Types of Qualified Mortgages
Summation

LIBRARY

 READ FULL ARTICLE 
 
 
  Read Full Article 
Read Article-1
 BACK 
  Professional AssistanceLCG 
Contact Us-2
 BACK 
LibraryLibrary

Law Library Image

Consumer Financial Protection Bureau

Summary of the Ability-to-Repay and Qualified Mortgage Rule
and the Concurrent Proposal
January 10, 2013

Protecting Consumers from Irresponsible Mortgage Lending
Fact Sheet
January 10, 2013
 BACK 
Suite of ServicesSuite
LENDERS COMPLIANCE GROUP is the first full-service, mortgage risk management firm in the United States specializing exclusively in outsourced mortgage compliance and offering a full suite of services in residential mortgage banking for banks and non-banks.

Pioneers in outsourcing solutions for mortgage compliance. 
 
 

Professional guidance and support to financial institutions!  

Mortgage Compliance 
CFPB Examination Preparation 
Anti-Money Laundering Compliance  
Legal and Regulatory Compliance  
State Banking Examinations 
HUD/FHA Examinations 
Loan Originator Compensation  
Licensing Compliance  
HMDA/CRA and Fair Lending 
Information Technology & Security 
Training and Education  
Quality Control 
Prefunding Fannie LQI Audits 
Platform Development  
Retail and Wholesale Compliance 
Correspondent Compliance 
Servicer Quality Assurance 
Affiliates Compliance (RESPA) 
Business Development 
Advertising Compliance  
Loss Mitigation Strategies 
Forensic Mortgage Services 
Agency Applications  
Sarbanes-Oxley Compliance (Part 404)  
Audit and Due Diligence Reviews 
Regulatory and Sales Training  
Portfolio Risk Management 
Credit Risk Management  
Loan Analytics Audits  
Compliance Audits 
Policies and Procedures 
Due Diligence Reviews  
Portfolio Purchase Audits 
Ginnie Mae Applications 

This communication is sent to our valued clients and colleagues, who regularly receive our Mortgage Compliance Updates, Compliance Alerts, Commentaries, and related publications.

These publications are free to subscribers. Information contained herein is not intended to be and is not a source of legal advice.

� 2006-2012 Lenders Compliance Group, Inc. All Rights Reserved.