- within Intellectual Property, International Law, Litigation and Mediation & Arbitration topic(s)
The CFPB stated that it expects to delay the July 1, 2021 mandatory compliance date of the General Qualified Mortgage ("QM") Rule and is considering whether to revoke or amend the "Seasoned QM" Rule.
As previously covered, on December 10, 2021, the CFPB adopted two rules that amend the definition of QMs under Regulation Z (the "Truth in Lending Act"):
- the General QM Rule, which replaces the 43 percent limit on a consumer's debt-to-income ratio; and
- the "Seasoned QM" Rule, which establishes a new QM category for transactions in which the loan (i) is secured by a first lien, (ii) has a fixed rate with payments that are fully amortizing and non-balloon, and (iii) has a term that does not exceed 30 years.
Both rules have March 1, 2021 effective dates. The General QM Final Rule has a mandatory compliance date of July 1, 2021.
The CFPB stated that it expects to issue a proposed rule "shortly" that would delay the July 1, 2021 mandatory compliance date of the General QM Rule. The CFPB also stated that it is considering whether to initiate a rulemaking that would revoke or amend the "Seasoned QM" Rule. The CFPB said it will consider whether to revisit other aspects of the General QM Rule at a later date.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
