ARTICLE
6 August 2019

Federal Register: CFPB Proposes Revisions To Qualified Mortgage Definition

CW
Cadwalader, Wickersham & Taft LLP

Contributor

Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
A CFPB proposal to change the definition of qualified mortgage in Regulation Z under the Ability to Repay/Qualified Mortgage Rule was published in the Federal Register.
United States Finance and Banking
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A CFPB proposal to change the definition of qualified mortgage in Regulation Z under the Ability to Repay/Qualified Mortgage Rule was published in the Federal Register.

As previously covered, the CFPB is considering whether a qualified mortgage (i) should be based on the direct measure of a consumer's personal finances, such as debt-to-income ratio or residual income, and how that measure should be structured, or (ii) should instead include an alternative method for assessing financial capacity (or should be limited to the express statutory criteria).

Comments on the proposed rulemaking are due by September 16, 2019.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

ARTICLE
6 August 2019

Federal Register: CFPB Proposes Revisions To Qualified Mortgage Definition

United States Finance and Banking

Contributor

Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
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