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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 CFPBís ability to repay rule is to change their ownership structure, according to a top industry compliance attorney. Loretta Salzano, a founding partner of Franzťn and Salzano, warned attendees at the recent Real Estate Settlement Providers Councilís 2014 annual conference that, ďLenders with affiliated providers must consider the ATRís 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.Ē 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...

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With originations expected to drop in 2018, will your shop turn to non-QM/non-prime mortgage products as a way to bolster volumes?

Yes, definitely. We’re planning a launch.


No. It’s still difficult compliance/regulatory-wise.


Maybe. It’s under consideration.


Not now. But things could change as 2018 progresses.