In just a few weeks, it will become clear whether the Consumer Financial Protection Bureaus ability-to-repay rule will be the industrys Y2K moment. But in the meantime, three top industry attorneys shared some final advice and guidance during a QM double check webinar sponsored by Inside Mortgage Finance last week. Joseph Reilly, a partner at BuckleySandler LLP, emphasized the critical importance of lenders documenting their compliance with the new regulation. If a tree falls...
FHA officials first asked for the servicing authority back in June, but the request has gone nowhere. Fannie Mae and Freddie Mac already have transfer authority.
A BuckleySandler lawyer reached into Zen lore to make his point. If a tree falls in the forest and no one hears it, does it make a sound? he asked. Similarly, Starting in 2014: If a lender complies with ATR/QM but cannot evidence it, has the lender complied?
The drop in warehouse commitments mirrored, somewhat, the fall-off in residential originations, which declined almost 19 percent in the third quarter, according to figures compiled by Inside Mortgage Finance.