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Volume 2014 - Number 23

June 12, 2014

Industry Groups Welcome CFPB’s Proposal for a Cure Period For QMs with Points and Fees that Exceed Allowable Limit

Industry groups are supportive of a proposal by the Consumer Financial Protection Bureau to provide a reasonable cure for inadvertent overages in points and fees on qualified mortgages, but they disagree over the appropriate length of the cure period and other issues. The proposed CFPB rule would amend certain mortgage rules issued last year under the Truth in Lending Act. It would provide a limited cure mechanism for QM loans that exceed the points-and-fees limit for such mortgages and provide an alternative “small servicer” definition for nonprofit groups that meet certain requirements. Also, the bureau has proposed to amend the current exemption from the ability-to-repay rule for qualified nonprofits. In addition to the specific proposals, the CFPB sought...

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