In the December 15, 2025 issue of the Federal Register (90 FR 57890 click here), the Consumer Financial Protection Bureau...
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Read articles below for analysis and discussion of recent trends by BM&G’s industry experts.
CFPB Issues Prepaid Interest Factsheet for Use in Price-based General QM APR Calculations
This memorandum notifies those clients who make or will make qualified mortgages (QM) subject to the price-based General QM...
CFPB Public Statement on General QM and Seasoned QM Final Rules
In the February 26, 2021 issue of the Federal Register (85 FR 11623) the Bureau of Consumer Financial Protection published a...
CFPB Final Rule Amends General Qualified Mortgage Loan Definition
In the December 29, 2020 issue of the Federal Register (85 FR 86308, click here) the Bureau of Consumer Financial Protection...
CFPB Creates New Category of Qualified Mortgages – Seasoned QM
In the December 29, 2020 issue of the Federal Register (85 FR 86402), the Consumer Financial Protection Bureau (CFPB) published...
Regulation Z HOEPA and Qualified Mortgage Annual Threshold Adjustments
In the August 19, 2020, issue of the Federal Register (85 FR 50944), the Consumer Financial Protection Bureau established the...
CFPB Proposed Rule to Amend General Qualified Mortgage Loan Definition
In the July 10, 2020 issue of the Federal Register (85 FR 41716, click here) the Bureau of Consumer Financial Protection...
Regulation Z HOEPA and Qualified Mortgage Annual Threshold Adjustments
In the August 1, 2019, issue of the Federal Register (84 FR 37565), the Consumer Financial Protection Bureau established the...
Assumptions – Are Loan Estimates and Closing Disclosures Required?
On May 1, 2019, the Consumer Financial Protection Bureau (CFPB) published a Factsheet discussing whether Loan Estimates and...
Asset-size Thresholds Revised for HMDA and TILA in 2018
In the December 27, 2017 issue of the Federal Register, the following annually revised asset-size thresholds were published to be effective January 1, 2018: Home Mortgage Disclosure Act/Regulation C (82 FR 61145) The CFPB has added comment -2 under the definition “Financial institution” in §1003.2(g) of the Staff Commentary to Regulation C (12 CFR part 1003) to increase the asset-size exemption threshold for banks, savings associations, and credit unions for HMDA data collected in 2018 to $45 million. Therefore, effective January 1, 2018, banks, savings associations, and credit unions with assets at or below $45 million as of December 31, 2017, are exempt from collecting HMDA data for 2018. (Note: An institution’s exemption from collecting HMDA data in 2018 does not affect its responsibility to report data it was required to collect in 2017.)