American Banker | Confusion over CFPB Underwriting Rule Persists | News & Insights

Advisories April 12, 2021

Financial Services & Products Advisory: Fannie Mae and Freddie Mac Sunset the QM Patch

The qualified mortgage (QM) rules have become a world of contradictions. Our Financial Services & Products Group investigates how the residential mortgage markets can thread the needle between new rulings from Fannie Mae and Freddie Mac and recent rulings from the Consumer Financial Protection Bureau.

Advisories February 24, 2021

Financial Services & Products Advisory: CFPB Delays Implementation of General QM Rule and May Jettison the “Seasoned QM” Rule

With a change in Administration, the Consumer Financial Protection Bureau changes its mind about qualified mortgage rules for residential mortgages. Our Financial Services & Products Group reviews how the Biden CFPB’s last-minute delay may upend the Trump Administration’s last-minute changes to the qualified mortgage rules.

Advisories December 12, 2023

Financial Services & Products Advisory: Complying with the “Consider” Requirement Under the Revised Qualified Mortgage Rules

The originators of residential mortgage loans are inconsistent in meeting the “consider” requirement under the revised qualified mortgage rules. Our Financial Services & Products Group offers guidance for creditors looking to comply with this requirement.

In the News December 19, 2022

American Banker | CFPB’s QM Rule Under Scrutiny After Dust-up over Bank Statement Loans

Stephen Ornstein is quoted on what lenders need to anticipate from the scrutiny around the Consumer Financial Protection Bureau’s QM rule and bank statements.

General Publications Fall 2021

“The QM Patch Is Down for the Count,” The Real Estate Finance Journal, Thomson Reuters, Fall 2021.

Somehow, the qualified mortgage (QM) rules have become even more complicated. This article parses how the death of the QM Patch will affect creditors seeking to originate residential mortgage loans under Fannie Mae, Freddie Mac, or Consumer Financial Protection Bureau regulations.