The proposed seasoned QM category is designed to encourage non-QM lending with additional legal certainty. But the eligibility requirements will make banks, thrifts and credit unions the main beneficiaries, or so it appears.

Of late, the CFPB has brought four enforcement actions against VA lenders for using deceptive mailers to advertise their government-backed products, assessing steep penalties. Similar regulatory actions are likely to follow.

The GSE refi fee, albeit delayed, ultimately will be passed to consumers, impacting loan pricing. Compliance and disclosure implications? Indeed.

But the scope of the proposal amended in mid-August is much narrower than the original, exempting existing state licensees, including mortgage lenders and servicers, from the California Consumer Financial Protection Law.

In particular, industry groups like the idea that third parties, including trade associations, can submit advisory opinion requests on behalf of companies, but consumer groups have their doubts.

In a motion to partially dismiss, the CFPB is trying to blunt a challenge by consumer groups over the creation and composition of its consumer financial law task force, arguing they are not directly harmed.

Need help from the CFPB on RESPA? Maybe not. A lack of specific rules, in fact, has enabled innovation in how settlement service providers interact with each other and refer customers.