Scott Samlin

Scott Samlin

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Federal Court Clarifies Banks' Obligations Under Appendix Q

The U.S. District Court for the Southern District of Ohio recently issued a landmark decision regarding the reasonableness of a bank’s reliance on Appendix Q regarding nonemployment-related consumer income validation for a...more

4/15/2019  /  Ability-to-Repay , Mortgages , Qualified Mortgage Rule , Qualifying Income , Reasonableness Factors , Regulation Z , Separation Agreement , Truth in Lending Act (TILA) , Verification Requirements

CFPB to Reconsider Payday Loan Rule

On January 16, the CFPB announced plans to “reconsider” its newly minted regulation for Payday, Vehicle Title, and Certain High-Cost Installment Loans (the Payday Rule)....more

1/22/2018  /  Ability-to-Repay , Banking Sector , Consumer Financial Products , Consumer Financial Protection Bureau (CFPB) , Consumer Lenders , Online Marketplace Lending , Payday Loans , Regulatory Oversight
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