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Special Alert: CFPB Finalizes Additional Amendments to the 2013 Mortgage Rules

Special Alert

Clinton R. Rockwell, Jeremiah S. Buckley, Joseph M. Kolar, John P. Kromer, Jeffrey P. Naimon

On September 13, the CFPB finalized another set of amendments to its January 2013 mortgage rules. Whereas previous amendments focused largely on the ability-to-repay/qualified mortgage rule, these amendments – originally proposed in late June 2013 – principally address several important questions that have emerged during the implementation process for the mortgage servicing and loan originator compensation rules. We have prepared a Special Alert regarding these latest amendments.

The amendments provide guidance on complying with the rules and, in several cases, the CFPB revised the proposed amendments in response to concerns raised by the industry during the comment period. Nevertheless, the volume and complexity of the new requirements and the number of outstanding issues still present a daunting task for many industry participants as they work to implement the rules by January 2014. The CFPB declined industry requests to provide additional time for compliance and, except as discussed in our Special Alert, has not indicated whether additional amendments will be forthcoming.

Questions regarding the matters discussed in the Alert may be directed to any of our lawyers listed below, or to any other Buckley Sandler attorney with whom you have consulted in the past.

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