Detailed Analysis of CFPB's Final Ability-to-Repay/Qualified Mortgage Rule


As promised in our earlier flash Alert on the Consumer Financial Protection Bureau's (the "Bureau") highly anticipated final "Ability-to-Repay" rule governing residential mortgage lending under Regulation Z (the "Rule"), we are providing in this Alert a detailed summary and analysis of the Rule, which becomes effective on January 10, 2014. We also assess the Bureau's concurrently issued proposal, which seeks comments by February 25, 2013 on potential amendments to the Rule. For ease of reference, this Alert contains a detailed, hyper-linked Table of Contents.