CFPB Publishes 2020 Rulemaking Agenda
On November 22, the CFPB released its list of regulatory matters that it “reasonably anticipates having under consideration during the period from October 1, 2019 to September 30, 2020.”
Of special interest to clients is the resolution of the so-called ‘GSE patch,’ meaning the Reg Z ‘qualified mortgage’ status for loans purchased by Fannie Mae and Freddie Mac, which is set to expire in January of 2021.
We noted the Advanced Notice of Public Rulemaking (ANPR) on the topic in our October newsletter, in which the CFPB requested input on possible changes to the Reg Z definition of ‘qualified mortgage’ to smooth the transition away from reliance on the patch. In addition, the CFPB noted that it is reviewing comments received on a March 2019 ANPR on Property Assessed Clean Energy (PACE) financing, often used to finance solar panel or other energy efficient improvements, in order to issue proposed amendments to Reg Z. The new regulations will address treatment of PACE loans under Reg Z ability-to-pay requirements and civil liability for violations, which may be changed in order to provide support for underlying energy-efficiency goals. Finally, the CFPB plans to issue a Notice of Proposed Rulemaking in July of 2020 to further define the collection and disclosure of data required by HMDA.
In this blog post concerning legal and regulatory matters of interest to the mortgage industry, Sandler Law Group (SLG) provides general information and industry observations that are not motivated by or concerned with a particular past occurrence or event, or a specific existing legal problem of which SLG is aware. Nothing published herein is intended to constitute legal advice and the use of the blog post by a reader shall not give rise to an attorney-client relationship with SLG. SLG expressly disclaims any representation of accuracy or reliability as to the content of this blog post, as well as any obligation to maintain such content over time or to ensure it is free from errors. Brad Cope is the attorney responsible for the SLG content of this blog post. Unless otherwise noted, the attorneys of SLG are not certified by the Texas Board of Legal Specialization.
Reg+Tech Magazine Vol. 1 Issue 2
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