The Consumer Financial Protection Bureau (“CFPB”) issued two relatively welcome surprises yesterday. First, along with ditching a debt-to-income ratio (“DTI”) ceiling, the agency expanded its proposed general Qualified...more
12/14/2020
/ Ability-to-Repay ,
Consumer Financial Products ,
Consumer Financial Protection Bureau (CFPB) ,
Fannie Mae ,
Financial Regulatory Reform ,
Financial Services Industry ,
Freddie Mac ,
GSE ,
HOEPA ,
Mortgages ,
Qualified Mortgage Rule
The implications of the 2020 election for structured finance are coming into focus. Informed by our discussions in Washington, we can anticipate the likely direction of federal policy over the next two years that will impact...more
12/9/2020
/ Biden Administration ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Financial Regulatory Reform ,
GSE ,
Infectious Diseases ,
Inter-Bank Offered Rates (IBORs) ,
Securities and Exchange Commission (SEC) ,
Securitization ,
Structured Finance ,
UK Brexit ,
Volcker Rule
As rumored, the Consumer Financial Protection Bureau (“CFPB”) is proposing to revise its general qualified mortgage definition by adopting a loan pricing test. Specifically, under the proposal, a residential mortgage loan...more
In a new era of double-digit unemployment resulting from the COVID-19 pandemic, it may be tough for a mortgage lender to predict the amount and stability of someone’s income in order to determine qualification for a home...more
6/10/2020
/ Ability-to-Repay ,
Borrowers ,
Consumer Financial Products ,
Coronavirus/COVID-19 ,
Fannie Mae ,
Financial Services Industry ,
Freddie Mac ,
Freelance Workers ,
GSE ,
Independent Contractors ,
Mortgage Loan Servicing Standards ,
Mortgages ,
Qualifying Income ,
Underwriting