Compliance Bulletin

Final CFPB ATR/QM Mortgage Rule Gives Relief to Small Lenders
November 20, 2015

Many banks and banking associations, including CBA, have urged the CFPB for a long time to broaden its “small creditor” exemption from a myriad of mortgage regulations, including the need to establish escrow accounts for higher priced mortgage loans, the 43 percent debt-to-income ratio, and applicability of the presumptive safe harbor from legal claims. Last month the CFPB raised from 500 to 2,000 the maximum number of covered loans a lender may make annually to be eligible for the small creditor exception, and made other changes favorable to small lenders. See CBA’s Regulatory Compliance Bulletin for more information.