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ARTICLE · 21 JANUARY 2019

CFPB Assesses ATR/QM And RESPA Mortgage Servicing Rules

Hogan Lovells Cadwalader
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In two new reports, the Consumer Financial Protection Bureau ("CFPB") assessed the impact of the Ability to Repay / Qualified Mortgage ("ATR/QM") Rule and the Real Estate Settlement Procedures Act ("RESPA") Mortgage Servicing Rule.

United StatesFinance and Banking

In two new reports, the Consumer Financial Protection Bureau ("CFPB") assessed the impact of the Ability to Repay / Qualified Mortgage ("ATR/QM") Rule and the Real Estate Settlement Procedures Act ("RESPA") Mortgage Servicing Rule. The rules took effect in January 2014.

The ATR/QM Rule (i) requires a mortgage lender to assess a borrower's ability to repay ("ATR") a mortgage loan, (ii) sets standards for classifying QM loans and (iii) establishes criteria and requirements for lenders to evaluate the ability of consumers to repay loans under the ATR requirement.

In one report, the CFPB found, among other things, that:

  • the introduction of the rule did not correlate with an enhancement in loan performance;

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