Today the CFPB issued its assessments of the Ability to Repay and Qualified Mortgage (ATR/QM) Rule and the Mortgage Servicing Rule (these are also sometimes referred to as the “lookbacks”). The assessments are required under section 1022(d) of the Dodd-Frank Act, which mandates that the CFPB publish an assessment of its significant rules within five years of the effective date of the rule. These assessments are important because they contain the Bureau’s analysis of significant issues under the rules, such as the temporary GSE QM “patch” under the ATR/QM rule, which will sunset on the earlier of the end of the GSEs’ conservatorship or receivership or January 10, 2021.
Stay tuned for a post on our analysis of these assessments. You can find these assessments at: https://www.consumerfinance.gov/about-us/newsroom/consumer-financial-protection-bureau-publishes-assessments-ability-repay-and-mortgage-servicing-rules/.
Please contact us if you would like to discuss these assessments, the ATR/QM rule, or the Mortgage Servicing rule.