The Ability to Repay (ATR) and Qualified Mortgage (QM) rules are outlined and analyzed, helping to bring greater clarity to the requirements. The paper also features an explanation of why the rules were created and how lenders and servicers can benefit from the transparency provided to build investor trust over time and increase the flow of private capital into the market.
In the second paper of the series, the re-proposed Credit Risk Retention (CRR) rule and Qualified Residential Mortgage (QRM) alternatives are outlined and analyzed, helping to bring greater clarity to the requirements. The paper also addresses the issue of QRM exemptions for the government-sponsored entities (GSEs) and the effect of the rules on loans outside the standard, such as jumbo loans.
This is the third installment in the four part series, this white paper reviews the nearly 40-year-old Home Mortgage Disclosure Act (HMDA) and its evolution since enactment in 1975. The paper explores the transfer of authority to the Consumer Financial Protection Bureau (CFPB), the new statutory data field requirements under the Dodd-Frank Act and the CFPB’s recently proposed expansion of additional fields that the CFPB has deemed appropriate.
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