The implications of the 2020 election for structured finance are coming into focus. Informed by our discussions in Washington, we can anticipate the likely direction of federal policy over the next two years that will impact...more
12/9/2020
/ Biden Administration ,
Consumer Financial Protection Bureau (CFPB) ,
Coronavirus/COVID-19 ,
Financial Regulatory Reform ,
GSE ,
Infectious Diseases ,
Inter-Bank Offered Rates (IBORs) ,
Securities and Exchange Commission (SEC) ,
Securitization ,
Structured Finance ,
UK Brexit ,
Volcker Rule
As rumored, the Consumer Financial Protection Bureau (“CFPB”) is proposing to revise its general qualified mortgage definition by adopting a loan pricing test. Specifically, under the proposal, a residential mortgage loan...more
In a new era of double-digit unemployment resulting from the COVID-19 pandemic, it may be tough for a mortgage lender to predict the amount and stability of someone’s income in order to determine qualification for a home...more
6/10/2020
/ Ability-to-Repay ,
Borrowers ,
Consumer Financial Products ,
Coronavirus/COVID-19 ,
Fannie Mae ,
Financial Services Industry ,
Freddie Mac ,
Freelance Workers ,
GSE ,
Independent Contractors ,
Mortgage Loan Servicing Standards ,
Mortgages ,
Qualifying Income ,
Underwriting
Many of you have read about the power of the president to invoke the Defense Production Act to acquire products or direct the activities of suppliers based on a finding that it is necessary for the federal government to...more
6/9/2020
/ CARES Act ,
Coronavirus/COVID-19 ,
Fannie Mae ,
Financial Distress ,
Forbearance Agreements ,
Freddie Mac ,
Ginnie Mae ,
GSE ,
Mortgage Servicers ,
Mortgages ,
Relief Measures
When the federal Consumer Financial Protection Bureau (“CFPB”) last summer issued its Advance Notice of Proposed Rule Making (“ANPR”) to revise the definition of a “Qualified Mortgage” (“QM”) under the Dodd-Frank Act’s...more
2/20/2020
/ Ability-to-Repay ,
Advanced Notice of Proposed Rulemaking (ANPRM) ,
Annual Percentage Rate (APR) ,
Assignees ,
ATR-QM ,
Borrowers ,
Consumer Financial Protection Bureau (CFPB) ,
Dodd-Frank ,
Financial Regulatory Reform ,
Financial Services Industry ,
GSE ,
HOEPA ,
Investor Protection ,
Loans ,
Mortgages ,
Qualified Mortgage Rule ,
Qualified Residential Mortgages (QRB) ,
Regulatory Oversight ,
Regulatory Requirements ,
Risk Retention ,
Rulemaking Process ,
Securitization ,
Threshold Requirements ,
Underwriting