Advanced Search

Volume 25 - Number 9

April 28, 2014

ABAs May Change Ownership Structure to Cope with ATR Rule

One option that some affiliated business arrangements can use as a mechanism to cope with the CFPB’s ability to repay rule is to change their ownership structure, according to a top industry compliance attorney. Loretta Salzano, a founding partner of Franzén and Salzano, warned attendees at the recent Real Estate Settlement Providers Council’s 2014 annual conference that, “Lenders with affiliated providers must consider the ATR’s impact on their business based on the number and type of affiliates, the break point based on fees of all affiliates, the average loan amount, and the markets served.” Part of that process means lenders have to look and see where their break point is, the point at which they will breach the 3 percent...

Subscribers to Inside the CFPB have full access to all its stories and data online. Visitors may become subscribers for full access or may purchase individual articles and data.

Subscriber Log In

If you are a current subscriber or already purchased this article, please login below.

Forgot your password?

Already subscribe but haven't registered for all the benefits of the website?


This biweekly keeps mortgage executives on top of the onslaught of new legal and regulatory issues the industry has been seeing.



You can purchase this article for $55.00 without subscribing and always have access to it on

Pay Per View

Please contact Customer Service if you need assistance: 1-800-570-5744


With the spring homebuying season in full swing, what percentage of your March 2017 application volume has been for “purchase” loans?

75% or higher
50% to 74%
30% to 49%
Under 30%

vote to see results