Bank Regulatory Newsletter
The Consumer Financial Protection Bureau’s new Ability-to-Repay and Qualified Mortgage Standards Rule is lengthy and complicated. It is not a disclosure rule but instead requires a creditor to revise loan products and its origination and underwriting practices, including compensation to its employees and third party loan originators. Following is a summary of significant parts of the Rule. The Rule provides compliance options, each which should be analyzed based on the creditor’s customers and its operational capabilities.