Now that the Consumer Financial Protection Bureau (CFPB) has finalized the "qualified mortgage" definition that forms the heart of the new ability-to-repay (ATR) mortgage rule mandated by the Dodd-Frank Act, mortgage lenders and regulators are shifting their focus to implementing these new underwriting requirements.
In coming months, in-house counsel and compliance staff should be on the lookout for key publications and guidance expected to be issued by the CFPB and the Federal Financial Institutions Examination Council (FFIEC) that are designed to help financial institutions conduct self-assessments of their lending processes and build effective compliance programs before the ATR rule kicks in next January. With the definition finalized, banks are also bracing for looming announcements on reforms of the secondary market for mortgage financing.
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