CFPB Residential Mortgage Rules

Ability to Repay and Qualified Mortgage Requirements

Click here to view product matrices for each of the potential mortgage types. The matrices have been compiled by IBAT's Regulatory Compliance Manager, Kelly Goulart, to help you prepare for the upcoming January deadlines. Each matrix covers the potential civil liability risk, the mortgage requirements and prohibitions by type, and minimum underwriting criteria.

CFPB Mortgage Compliance Guides

CFPB Mortgage Rule Clarification Series

In order to provide additional clarification on the recently issued CFPB mortgage reforms, IBAT Regulatory Compliance Manager Kelly Goulart is releasing a series of white papers addressing each change contained in the seven major mortgage lending initiatives.  

The seventh and final part of the series, focused on mortgage loan originator compensation, is now online.

Previous documents in the series can be found here:

FAQs on Dodd-Frank Act Mortgage Rules

On February 21, 2013, IBAT General Counsel Karen Neeley presented the webinar above on the CFPB residential mortgage rules.  The webinar was followed by a lively question and answer session.  Ms. Neeley compiled those questions and answers, plus others, into an FAQ on the CFPB’s Residential Mortgage Rules that IBAT is making available to its members. 

CFPB Designates "Rural and Underserved" Counties

Final 2018 Lists

Rural or Underserved Counties

CSV | XLS | PDF

Rural Counties

CSV | XLS | PDF

Some entities that do business in rural or underserved counties are exempt from certain regulatory requirements of the Truth in Lending Act.

In addition to these lists, lenders should also use the CFPB’s Rural or Underserved Areas Tool to provide a safe harbor determination that a property is located in a rural or underserved area as defined in 12 CFR 1026.35(b)(2)(iv)(A) and (B). The tool is more comprehensive than the lists because the lists reflect rural status only at the county level; the tool includes both locations that are rural because they lie in rural (non-urban) census blocks and locations that are rural because they lie in rural counties.

These lists include the following U.S. territories as rural areas in their entireties: Guam, the Commonwealth of the Northern Mariana Islands, American Samoa, and the U.S. Virgin Islands. These territories comprise areas that the U.S. Census Bureau treats as counties and that are neither metropolitan statistical areas or micropolitan statistical areas adjacent to metropolitan statistical areas.

Historical lists can be found here.

CFPB Mortgage Reform Exemption Analysis

It is certain that the new mortgage lending compliance requirements issued by the CFPB will have a considerable impact upon community banks across Texas. Of the seven major mortgage lending compliance initiatives required under Dodd-Frank, six have been finalized. Three of the four have an exemption either finalized or proposed targeting small, rural lenders. This single page handout is intended to help you understand the practical considerations of the exemption qualifications in general and what specifically is being exempted.

Regulators Offer Help with Mortgage-related Final Rules

The CFPB published a Small Entity Compliance Guide for the Ability-to-Repay and Qualified Mortgage Rule to provide a rule summary in a plain language and FAQ format.  The CFPB also issued a chart comparing Ability-to-Repay with Qualified Mortgages.