On December 23, the CFPB published a final rule in the Federal Register regarding various annual adjustments it is required to make under provisions of Regulation Z (TILA) that implement the CARD Act, HOEPA, and the ability to repay/qualified mortgage provisions of Dodd-Frank. The adjustments reflect changes in the Consumer Price Index (CPI) in effect on June 1, 2022 and will take effect January 1, 2023.… Continue Reading
qualified mortgage
President Biden replaces FHFA Director based on Supreme Court decision—Now what happens?
On June 23, 2021, President Biden replaced the Federal Housing Finance Agency (FHFA) Director Mark Calabria with Acting Director Sandra L. Thompson.
The move was made possible by the decision of the U.S. Supreme Court earlier in the day holding that the FHFA structure is unconstitutional because the Director could be removed by the President only for cause. … Continue Reading
CFPB proposes to delay mandatory compliance date for new general qualified mortgage
The CFPB has proposed to delay the mandatory compliance date for the new general qualified mortgage (QM) rule that amends the Regulation Z ability to repay/QM rule from July 1, 2021 to October 1, 2022. As previously reported, in December 2020, a little over a month before former Director Kraninger resigned, the CFPB issued two final QM rules. … Continue Reading
Acting Director Uejio outlines regulatory priorities and seeks options for putting QM and debt collection rules on hold
In a blog post published at the end of last week, Acting CFPB Director Uejio shared with the public the statement that he sent to the staff of the Bureau’s Division of Research, Markets, and Regulations (RMR) outlining his regulatory priorities and directing staff to “explore options for preserving the status quo with respect to QM and debt collection rules.”… Continue Reading
CFPB publishes annual CARD Act, HOEPA and QM adjustments, corrects 2016 error
The CFPB has published a final rule regarding various annual adjustments it is required to make under provisions of Regulation Z (TILA) that implement the CARD Act, HOEPA, and the ability to repay/qualified mortgage provisions of Dodd-Frank. The adjustments reflect changes in the Consumer Price Index in effect on June 1, 2016 and will take effect January 1, 2017.… Continue Reading
CFPB publishes annual CARD Act, HOEPA and QM adjustments
The CFPB has published a final rule regarding various annual adjustments it is required to make under provisions of Regulation Z (TILA) that implement the CARD Act, HOEPA, and the ability to repay/qualified mortgage provisions of Dodd-Frank. The adjustments made by the final rule are effective January 1, 2016.
The CARD Act requires the CFPB to calculate annual adjustments of (1) the minimum interest charge threshold that triggers disclosure of the minimum interest charge in credit card applications, solicitations and account opening disclosures, and (2) the fee thresholds for the penalty fees safe harbor. … Continue Reading
CFPB QM cure and other mortgage rule amendments now effective; HUD nixes CFPB cure for FHA QM rule
The CFPB’s final rule amending certain provisions of the 2013 Title XIV final mortgage rules which includes a post-consummation points and fees cure mechanism for qualified mortgage loans, became effective on Monday, November 3, when it was published in the Federal Register. (The only exception is a commentary revision in the final rule dealing with the relationship between the QM cure and the RESPA/Regulation X tolerance cure under the
TILA-RESPA integrated disclosure rule that becomes effective next year.) … Continue Reading
CFPB finalizes amendments to mortgage rules
The CFPB has issued a final rule amending certain provisions of the 2013 Title XIV final mortgage rules. While in its press release the CFPB describes the amendments as “minor adjustments to its mortgage rules,” the final rule contains several major changes from the CFPB’s proposal.
QM Points and Fees Cure. … Continue Reading
CFPB publishes annual CARD Act, HOEPA and QM adjustments
The CFPB has published a final rule regarding various annual adjustments it is required to make under provisions of Regulation Z (TILA) that implement the CARD Act, HOEPA, and the ability to repay/qualified mortgage provisions of Dodd-Frank. The adjustments made by the final rule are effective January 1, 2015.
The CARD Act requires the CFPB to calculate annual adjustments of (1) the minimum interest charge threshold that triggers disclosure of the minimum interest charge in credit card applications, solicitations and account opening disclosures, and (2) the fee thresholds for the penalty fees safe harbor. … Continue Reading
CFPB to issue whitepaper on methodology for identifying auto finance discrimination and consider use of advisory opinions
While Director Cordray’s appearance at the House Financial Services Committee’s hearing on the CFPB’s fifth Semi-Annual Report yesterday was accompanied by the usual dose of political theater, his testimony did yield the following items of noteworthy information:
- The CFPB will be issuing a white paper later this summer regarding use of the proxy methodology for identifying discrimination in indirect auto financing.