Ability to Repay / Qualified Mortgage

Ability to Repay / Qualified Mortgage

07.31.17
07.22.14
The Urban Institute analyzes the VA residual income underwriting standard....Read More
07.07.14
CMC comment letter on a potential cure or correction for erroneous QM DTI overages...Read More
12.22.13
Updated December 20, 2013...Read More
11.24.13
CMC letter to S&S agencies on Title XIV rules August 2013...Read More
11.24.13
July 2013 CFPB revisions to servicing rules, QM exemptions, and HPML rules...Read More
11.24.13
October 2013 revisions to loss mit, originator compensation, and ability-to-repay rules...Read More
11.11.13
Proposed and Final Rules...Read More
07.24.13
Final Revisions July 24, 2103 Proposed and Final Rules...Read More
06.12.13
Final QM June 2013 Proposed and Final Rules...Read More
02.25.13
CMC QM comment on points and fees, originator compensation, and other issues....Read More
02.25.13
The definition of points and fees is critical. While there has been a definition of points and fees for years under the Home Ownership and Equity and Protection Act of 1994 (“HOEPA”),1 it has not been significant because lenders have been unwilling to make HOEPA loans. The Rule will make the definition of points and fees a central issue in mortgage lending because the Rule will create enormous litigation risk for loans that are not qualified mortgage (“QM”) loans within the safe harbor, and because points and fees on QM loans are generally capped at three percent of the loan amount. 1 Home Ownership and Equity Protection Act of 1994, Pub. L. No. 103-325, §§ 151–158, 108 Stat. 2160, 2190-2198 (1994) (codified as amended in scattered sections of the Truth in Lending Act, 15 U.S.C. §§ 1601–1667f). 600 Cameron Street, Alexandria, VA 22314 Telephone: (202) 617-2101 Fax: (202) 318-8587  We would like to observe that the cap on points and fees is not, in any way, related to whether a consumer is able to repay a loan or whether a creditor has sufficiently underwritten a loan. The cap is simply a form of price regulation. The cap will not limit creditors’ ability to recoup their costs, but it will change the method by which they do so, replacing recoupment through points and fees with recoupment through interest rates. The cap will limit consumers’ ability to elect to pay more points in exchange for a lower interest rate. Especially when interest rates are high, this lack of flexibility to choose will harm consumers, and will cause them to pay more over the life of the loan than they would otherwise pay, absent the price cap....Read More
01.31.13
Final QM January, 2013 Proposed and Final Rules...Read More
01.30.13
Part II Bureau of Consumer Financial Protection 12 CFR Part 1026 Ability-to-Repay and Qualified Mortgage Standards under the Truth in Lending Act (Regulation Z); Final Rule...Read More
07.09.12
The definition of a QM loan is particularly important because it is likely, with rare exception, that lenders will be unwilling to make non-QM loans due to the liability that will attach to them. It is important that creditors and investors be able to distinguish between QM and non-QM loans so they can protect themselves from liability that was designed to attach only to non-QM loans. This necessitates a rule that is very well- defined. The degree of protection from liability and the definition of a QM loan will largely determine the availability of consumer mortgage credit nationwide. Clearly, though, the QM definition should be very broad and cover the majority of borrowers....Read More
04.16.12
The Honorable Richard Cordray Director Consumer Financial Protection Bureau 1700 G Street, N.W. Washington, DC 20552...Read More
07.22.11
Qualified Mortgage Proposed Rule Docket No. R-1417 RIN No. 7100-AD75...Read More