We have now surpassed 2 months since the Consumer Financial Protection Bureau (CFPB) Mortgage Rules became effective. Hopefully most credit unions have implemented the new rules and are monitoring your compliance with them. For those credit unions looking for additional guidance, you can rest assure that it looks like the regulatory agencies will continue to provide guidance with these new rules.
The NCUA released Regulatory Alert 14-RA-09, which covers “Updated Ability-to-Repay and Qualified Mortgage Requirements from the Consumer Financial Protection Bureau (CFPB).” This Regulatory Alert will supersede the Alert released in January of this year, and clarifies points and fees limit for each loan amount threshold and types of charges included in the calculation. The Alert also references updated guidance for implementing the requirements of the rule.
The new Regulatory Alert also includes an updated “Ability-To-Repay & Qualified Mortgage Rule Small Entity Compliance Guide” as an attachment as well.
Please take the time to review this Alert and the updated Guide to help you through these early stages of the new CFPB Mortgage Rules.