The CFPB has released a Comparison chart and Small Entity Compliance guide intended to help institutions understand the requirements of the Ability to Repay/Qualified Mortgage final rule. The Comparison chart illustrates the differences between the general ability to repay requirements and the requirements for originating qualified mortgage loans. While the Guide is in a Q&A format intended to be easier to read, the CFPB does not consider either the Chart or the Guide to be a suitable replacement for reading the rule itself.
You may have also seen the CFPB released another proposal intended to provide additional clarification on the Final Ability to Repay/Qualified Mortgage and Mortgage Servicing Rules. The proposal addresses the preemption of state laws; the determination of a small servicer, including when loans are serviced on a charitable basis; the government program eligibility status for certain loans to qualify as special qualified mortgages; and the requirements for qualified mortgages under Appendix Q. The proposal does not include any significant changes, but it could lessen the burden a little bit. I guess we’ll take what we can get, right? We will continue to monitor this proposal to see how and when it is finalized.
Diane joined Banker’s Compliance Consulting with over 10 years of compliance experience and over 15 years of experience within the financial industry. Diane is a Certified Regulatory Compliance Manager (CRCM) and has a Bachelor’s Degree in Sociology with a concentration in Criminal Justice. She is a graduate of the Schools of Banking Compliance School and has participated in various other training opportunities throughout her career. Diane understands firsthand the struggles banks face in building and maintaining successful compliance programs. Her experience and common sense approach to consumer compliance is a great asset to our clients.
Diane and her husband have two kids who keep them busy. She enjoys running and other sports and is a big Bugs Bunny fan! She’s a bit crazy in that she does enjoy reading some of these regulations and she’s a “crazy cat lady!” Her cat tales are hilarious!