It will take a while to digest the CFPB’s nearly 1,700-page release on payday, title and high-rate installment lending but, naturally, I have a number of preliminary observations:
- It remains highly uncertain that the Rule will ever go into effect.
HUD Issues Proposal to Avoid FHA Loans From Being Prohibited Starting Next Year
On March 13, 2014, HUD published a proposal to eliminate the requirement that an FHA loan borrower be required to pay interest after the loan is prepaid. The move is needed because the requirement would effectively cause FHA loans to …
CFPB adopts ability to repay rule amendments
On May 29, 2013, the CFPB adopted amendments to the final ability to repay rule. The CFPB had proposed the amendments on the same day that it issued the ability to repay rule in January 2013. The amendments are …
CFPB proposes clarifications and changes to Ability to Repay and Servicing Rules
In keeping with its promise to provide further guidance to the industry on the recent mortgage loan rules, the CFPB recently issued proposed clarifications and changes to the ability to repay/qualified mortgage rule and the servicing rules. Comments on the …
Quoth the CFPB: “Nevermore” on loans made to consumers who can’t repay
On January 10, 2013, the CFPB issued the long-awaited ability to repay/qualified mortgage rule and, while the devil will be in the details, it appears that cautious optimism for the mortgage industry is warranted. The industry fought hard for the …
Congressional draft letter favors QM “safe harbor”
U.S. Representatives Capito (R, WV) and Sherman (D, CA) are circulating a draft of a letter on the Hill which urges the CFPB to “craft a safe harbor [in the Ability to Repay/QM rule] that strikes the right balance between …
CFPB’s final Ability-to-Repay rule anticipated in early 2012
As my fellow blogger, Chris Willis, indicated in his prior post, Raj Date, the current acting director of the Consumer Financial Protection Bureau, has been actively previewing the CFPB’s forthcoming rule-making priorities. Indeed, in another speech at the American …
How the CFPB can help mortgage lenders
Banks that offer mortgage products are being buried in new regulations that are straining their compliance capabilities, increasing their costs and, for community banks, threatening the viability of their entire business model. That’s the message the American Bankers Association tried …