points and fees

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H.R. 3211, which amends the Truth in Lending Act’s definition of “points and fees,” was passed by a voice vote in the House of Representatives on June 9, 2014.  

The “points and fees” definition is used to determine whether a mortgage loan triggers application of the TILA high-cost mortgage loan provisions under the points and fees test, and whether a loan satisfies the points and fees limitation to be a qualified mortgage loan under the TILA ability to repay provisions. … Continue Reading

The CFPB published a Proposed Rule offering three specific amendments to the 2013 Title XIV Final Mortgage Rules. The proposed amendments respond to concerns about origination and servicing issues. 

In particular, the Proposed Rule would: (1) create a limited, post-consummation cure mechanism for mortgage loans thought to be qualified mortgages (QMs) at origination but that actually exceed the points and fees limit for QMs, (2) provide an alternative definition for the term “small servicer” that would apply to certain nonprofit entities that service mortgage loans, and (3) amend the ability-to-repay (ATR) requirements to allow certain subordinate-lien loans originated by nonprofit creditors to be excluded from the credit extension limit used for determining whether a nonprofit is exempt from the ATR requirements.… Continue Reading