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:
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 be prohibited under CFPB rules starting in January 2015. Comments on the proposal are due
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 effective on January 10, 2014, the same date that the ability to repay rule becomes
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 proposal will be due 30 days after it is published in the Federal Register.
The
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 creation of a safe harbor for qualified mortgages and the rule includes a 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 protecting consumers from poorly underwritten mortgages while ensuring they have access to safe and affordable
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 Banker’s Regulatory Symposium last week, Mr. Date elaborated on the CFPB’s goals with regard to
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 to send in its recent letter to Raj Date, President Obama’s replacement for Elizabeth Warren