CFPB Proposes Delay To Compliance Date For General Qualified Mortgage Amendment

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Cadwalader, Wickersham & Taft LLP

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The CFPB proposed a delay - from July 1, 2021 to October 1, 2022 - for compliance with an amended definition of the General Qualified Mortgage category under the Truth in Lending Act.
United States Finance and Banking
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The CFPB proposed a delay (from July 1, 2021 to October 1, 2022) for compliance with a December 2020 amendment to the definition of the General Qualified Mortgage ("QM") category under Regulation Z ("Truth in Lending Act").

As described in previous coverage, CFPB adopted amendments in December 2020 that replaced the 43 percent limit on a consumer's debt-to-income ratio ("DTI") with a limit based on loan pricing, providing higher thresholds for (i) smaller loan amounts, (ii) certain manufactured housing loans and (iii) subordinate-lien transactions. CFPB explained that for applications received between March 1, 2021 and October 1, 2022, creditors would have the option of complying with either the revised, price-based General QM definition or the DTI-based General QM definition.

Comments on the proposal must be received by April 5, 2021.

Primary Sources

  1. CFPB Press Release: CFPB Proposes Delay of Mandatory Compliance Date for General Qualified Mortgage Final Rule
  2. Federal Register: Qualified Mortgage Definition Under the Truth in Lending Act (Regulation Z): General QM Loan Definition; Delay of Mandatory Compliance Date

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.

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