Links in “Ability to Repay (ATR)/Qualified Mortgage (QM)”
- Potential Pitfalls in the Approach Your CU Takes in Determining Ability to Pay
If your CU chooses to only consider a consumerâs independent income and assets, it could be risking ECOA/Reg. B violations based on sex or marital status. [6/11]
- Newly Released Exam Manuals Can Help Compliance with New Mortgage Regulations
CFPB releases two new examiner manuals that cover compliance with the Truth-in-Lending Act (Reg. Z) and the Equal Credit Opportunity Act (Reg. B); yet to be addressed are the new mortgage servicing rules or the ability to repay rules, but the CFPB has advised that this information should be added in the next few months. [6/6]
- Final Final (That’s Final Squared) Ability to Repay Rule
Among the list of "final final" rule modifications is the inclusion of loan originator compensation in the points and fees calculation. [5/31]
- Does Your CU Qualify for Exemption from Mortgage Ability-to-Pay Rule?
CFPB issues final rule establishing an exemption for small CUs from mortgage ability-to-pay provisions; rule also finalizes provisions dealing with the prohibition against financing certain insurance provisions for mortgage loans. [5/30]
- Ability to Repay Gets CFPB Smoothification
The nearly 300 pages of Addendum may bring into possible doubt CFPB's stated commitment to "working with industry and consumers for a smooth transition to the new rules." [5/30]
- Digging Deeper into Ability to Pay Rules
When determining whether to issue an applicant a credit card, CUs may consider whether consumers 21+ have a "reasonable expectation of access" to income and assets, but are they required to? [5/28]
- CFPB Clarifies Escrow Rule Definitions of “Rural” and “Underserved”
Efforts to clarify rules on borrowersâ ability to repay higher-priced mortgages for higher-priced loans continues. [5/20]
- Head of CFPB to Realtors: No More Ninja Loans
Tells realtors the Ability-to-Repay rule is the most important new mortgage rule. [5/15]
