CFPB Issues Much Anticipated Final Rules: Ability to Repay, Qualified Mortgages, Escrow Requirements and Homeownership Counseling

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1 CFPB Issues Much Anticipated Final Rules: Ability to Repay, Qualified Mortgages, Escrow Requirements and Homeownership Counseling The Consumer Financial Protection Bureau ( CFPB ) issued their much anticipated final rules implementing various sections of the Dodd Frank Wall Street Reform and Consumer Protection Act ( DFA ) impacting Regulation Z (Truth in Lending ( TILA )) and Regulation X (Real Estate Settlement Procedures Act ( RESPA )) on January 10, Ability to Repay and Qualified Mortgages The Ability to Repay and Qualified Mortgage Rule ( ATR and QM Rule ) implements an ability to repay standard for creditors, and establishes protection from liability for the ability to repay requirements for qualified mortgages. This rule is effective January 10, 2014, thus giving financial institutions one year to prepare for these requirements. The Rule prohibits a creditor from making a consumer loan secured by a dwelling (except as set forth below) ( Covered Transaction ) unless the creditor makes a reasonable and good faith determination, at or before consummation, that the consumer will have a reasonable ability to repay the loan according to its terms. It is important to note that by definition a Covered Transaction does not include a home equity line of credit, mortgage loan secured by a timeshare, reverse mortgage, temporary or bridge loan meeting certain requirements, or the construction phase of a construction-to-permanent loan. Creditors are required to consider, at a minimum, the following eight underwriting factors in determining ability to repay: Current or reasonably expected income or assets; Current employment status; Monthly payment on the Covered Transaction; Monthly payment on any simultaneous loan; Monthly payment for mortgage related obligations; Current debt obligations, alimony and child support; Monthly debt to income ratio or residual income; and Credit history. A creditor must generally verify the information relied on to determine the consumer s ability to repay by using reasonably available third-party records. A new Appendix Q of Regulation Z ( Reg Z ) provides detailed guidance on the use and analysis of the underwriting factors covered by the ATR and QM rule. A creditor need not comply with the repayment ability requirements if it is refinancing a nonstandard mortgage that it currently holds or services on behalf of the holder if certain additional conditions are met. These additional conditions include the belief by the creditor that the refinance will likely prevent a default in the non-standard mortgage once the loan is recast. 1

2 Many in the industry feared that the CFPB would only provide a rebuttable presumption of compliance with the ability to repay requirements for loans meeting the qualified mortgage standards, as opposed to a complete safe harbor. The ATR and QM Rule in its final form provides a safe harbor for compliance with the ability to repay requirements with respect to loans that meet the qualified mortgage standards and are not considered higher priced loans. To be a qualified mortgage under the ATR and QM Rule, the loan must have the following characteristics: Regular periodic payments that are substantially equal that do not result in negative amortization, and does not allow a deferral of principal or a balloon payment except in certain limited instances; A loan term of no more than 30 years; A limit on points and fees that is dependent on the size of the loan (all dollar amounts will be adjusted annually for inflation) as follows: o For a loan of $100,000 or more, 3% of the total loan amount; o For a loan greater than or equal to $60,000, but less than $100,000, $3,000; o For a loan greater than or equal to $20,000, but less than $60,000, 5% of the total loan amount; o For a loan greater than or equal to $12,500, but less than $20,000, $1,000; o For a loan of less than $12,500, 8% of the total loan amount; Underwriting of the loan considers: o The monthly payment for mortgage related obligations using the maximum rate that will apply for the first 5 years, and periodic payments of principal and interest that will repay either: The outstanding principal balance over the remaining term of the loan as of the date the interest rate adjusts to the maximum rate identified above; or The loan amount over the loan term; o The creditor has verified the consumer s current reasonably expected income, assets and current debt obligations, alimony and child support; and o The consumer s debt to income ratio at the time of consummation does not exceed 43% as calculated in accordance with the ATR and QM Rule and Appendix Q; No balloon payments except in limited circumstances involving small portfolio creditors operating in rural or underserved areas; No prepayment penalties except in limited circumstances involving fixed rate qualified mortgages that are not higher priced loans if the prepayment penalty applies only during the first 3 years and is not greater than 2% during the first 2 years and 1% during the third year after consummation, and the creditor also offers a loan without a prepayment penalty to the consumer. A Higher Priced Covered Transaction is defined as a loan with an annual percentage rate that exceeds the average prime offer rate ( APOR ) for a comparable transaction as of the date the interest rate is set by: 2

3 1.5 or more percentage points for a first lien Covered Transaction; or 3.5 or more percentage points for a subordinate lien Covered Transaction. For loans considered to be Higher Priced Covered Transactions the rule provides only a rebuttable presumption of compliance with the repayment ability requirements. To rebut this presumption of compliance, the consumer must prove that, despite meeting the requirements of a qualified mortgage, the creditor did not make a reasonable and good faith determination of the consumer s repayment ability at the time of consummation. The consumer must show that the consumer s income, debt obligations, alimony, child support, and the consumers monthly payment (including mortgage related obligations) on the Covered Transaction and on any simultaneous loans of which the creditor was aware at consummation would leave the consumer with insufficient residual income or assets with which to meet living expenses, including any recurring and material non-debt obligations of which the creditor was aware at the time of consummation. Acknowledging that the ATR and QM Rule may have a negative impact on the still recovering housing market by reducing access to credit for those unable to qualify for a qualified mortgage, the ATR and QM Rule provides a temporary safe harbor for loans that are eligible to be purchased, guaranteed or insured by Fannie Mae and Freddie Mac, or any of their successor entities, or by HUD, the US Department of Veterans Affairs, the US Department of Agriculture or the Rural Housing Service. For the GSE s this temporary safe harbor exists until the earlier of January 10, 2021 or until they exit government conservatorship or receivership. For the other identified agencies the temporary safe harbor exists until the earlier of each agency s issuance of a rule of their own to define a qualified mortgage, or until January 10, The ATR and QM Rule also extends to 3 years the record retention period for records relating to Section , Minimum Standards for Transactions Secured by a Dwelling. This timeframe better coincides with the DFA s extension of the statute of limitations for civil liability for violations of the prepayment restrictions and ability to pay requirements. Escrow Rule On January 10, 2013, the CFPB also issued a final rule that implements changes required by the DFA which require that the time period be extended during which mandatory escrow accounts for closed-end higher priced mortgage loans must be maintained ( Escrow Rule ). The Escrow Rule is effective June 1, The Escrow Rule: Extends the existing period a creditor must establish and maintain an escrow account for a higher priced mortgage loan from 1 year to 5 years; Expands the existing exemption for insurance premiums for condominium units to include other situations in which a consumer s property is covered by a master insurance policy; 3

4 Exempts loans secured by shares in a cooperative, loans to finance the initial construction of a dwelling, temporary or bridge loans with a term of less than 12 months and reverse mortgages; Provides a narrow exemption for small creditors operating in rural and underserved areas, and that meet the following conditions: o More than 50% of the creditor s Covered Transactions were made in rural or underserved counties during the preceding calendar year; o Originated fewer than 500 first lien Covered Transactions in the previous calendar year, including those originated by affiliates; o Has less than $2 Billion in assets at the end of the preceding calendar year (this amount will be adjusted annually);and o Generally do not escrow for any mortgage obligations that it or its affiliates currently service, except in limited circumstances. Homeownership Counseling On January 10, 2013, the CFPB also issued a rule that expands the type of mortgage loans subject to the Home Ownership and Equity Protections Act of 1994 ( HOEPA ); revises the tests for coverage under HOEPA; and imposes additional protections for consumers, including homeownership counseling ( Homeownership Counseling Rule ). The Homeownership Counseling Rule includes amendments to both TILA and RESPA and is effective January 10, The Homeownership Counseling Rule amends Reg Z to expand the coverage of HOEPA by modifying the definition of a high-cost mortgage to include any consumer credit transaction secured by the consumer s principal dwelling, and in which: The APR exceeds the APOR for a comparable transaction by more than: o 6.5% for a first lien transaction, other than those where the dwelling is personal property and the loan amount is less than $50,000; or o 8.5% for a first lien transaction if the dwelling is personal property and the loan amount is less than $50,000; or o 8.5% for a subordinate lien transaction; or The transaction s total points and fees, as defined in the regulation, will exceed (all dollar amounts below will change annually): o 5% of the total loan amount if the loan is $20,000 or more; or o The lesser of 8% of the total loan amount or $1,000 if the loan amount is less than $20,000; or The credit documents allow the creditor to charge a prepayment penalty more than 36 month after consummation, or prepayment penalties that can exceed more than 2% of the amount prepaid. The Homeownership Counseling Rule provides additional guidance on the applicability of the coverage tests and various calculations required. The only loans that now may be exempt from possible HOEPA requirements are: 4

5 Reverse mortgages; Loans to finance the initial construction of a dwelling; Loans originated and financed by a Housing Financing Agency; and Loans originated under the United States Department of Agriculture s Rural Development Section 502 Direct Loan Program. The Homeownership Counseling Rule also implements additional DFA restrictions and requirements for high-cost mortgages, including: Balloon payments (defined as more than two times a regular periodic payment) are generally not allowed, unless they are a result of adjustments for seasonal or irregular income of the consumer, are part of bridge loan with a term of 12 months or less used for the acquisition or construction of a dwelling that will become the consumer s principal dwelling; or meet the requirements for balloon payments under qualified mortgages, and the creditor operates predominately in rural or underserved areas. Prepayment penalties are prohibited. Demand features are prohibited, unless there is fraud or material misrepresentation, default in payments required under the loan, or any action or inaction by the consumer that adversely affects the creditor s security, or any right in the security, for the loan. Creditors making HELOCs are required to determine the consumer s ability to repay in accordance with the specific requirements in the regulation. A certification of pre-loan counseling as required in the regulation must be obtained before consummation. Creditors are prohibited from recommending or encouraging default on an existing loan that will be refinanced with a high-cost mortgage. Fees to modify, renew, extend or amend a high-cost mortgage, or to defer a payment are prohibited. Late fees may not exceed 4% of the amount of the past due payment. Fees for payoff statements are restricted. Points and fees may not be financed. Creditors must provide consumers with a written list of homeownership counseling organizations meeting certain requirements not later than 3 business days after receipt of an application for a mortgage loan (mortgage loans secured by a timeshare and reverse mortgages are excluded.) The new rules finalized by the CFPB once again provide for complex and detailed changes in the manner in which mortgage lending is conducted. It is imperative that these changes are understood and incorporated into the financial institution s processes to avoid both regulatory scrutiny and civil liability. Contact any member of the Financial Institutions Practice Group listed below to learn more about these new regulations. 5

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