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Complying with the CFPB's Qualified Mortgage Rule: Issues for Implementation

February 05, 2013

By THE GLOBAL BANKING AND PAYMENT SYSTEMS PRACTICE

This client alert discusses the so-called ability-to-repay or Qualified Mortgage final rule published by the Consumer Financial Protection Bureau (CFPB) on January 30, 2013. The rule implements sections 1411 and 1412 of the Dodd-Frank Act, which amend Regulation Z to require mortgage lenders to take into account a borrowers ability-to-repay when making a mortgage loan. The client alert discusses particular issues and concerns raised by the rule, as well as the potential impact on the rule (and the CFPB) from the recent Federal Court of Appeals case striking down the recess appointments of three NLRB members who were appointed on the same day as CFPB Director Richard Cordray was recess appointed to the CFPB.