Last week, the Consumer Financial Protection Bureau (CFPB) finalized corrections, clarifications, and amendments to its Ability-to-Repay and mortgage servicing rules. These were first proposed in April of this year, and the Missouri Credit Union Association (MCUA) filed a comment letter with the agency on June 3, which can be located here.
Among other things, the final rule (1) clarifies how to determine a consumer’s debt- to-income ratio under the Ability-to-Repay rule, by amending how several factors can be used to calculate the ratio; (2) explains that the CFPB’s RESPA rule does not preempt the field of servicing regulation by states by adding a comment to explain how RESPA preemption works; (3) establishes which mortgage loans to consider in determining small servicer status(for example, loans serviced on a charitable basis do not have to be counted in this determination); and (4) clarifies the eligibility standard of the temporary qualified mortgage provision for purposes of underwriting a loan based on government sponsored enterprise or agency standards such as those required by Fannie Mae and Freddie Mac.
For more information on the final rule, click here. CUNA will be preparing a Final Rule Analysis on this in the near future.