The CPFB recently issued another update to the Small Entity Compliance Guide for the Ability-to-Repay and Qualified Mortgage Rule, to reflect changes from the October 2013 Final Rule.  The updated guide clarifies several aspects of the QM points and fees calculation, per the October 2013 Final Rule.  A new provision is included, which emphasizes that while a charge paid by a third party, and not by the consumer, might not be included in the finance charge element of points and fees (i.e.,… Continue Reading