Updates to TILA Interagency Guidance and Certain Annual Thresholds
Troutman Sanders
OCTOBER 28, 2021
The rules in question were issued by the Consumer Financial Protection Bureau (CFPB) in 2020 and 2021. The updates reflect changes to the definition of a General QM loan and the addition of a new category of QM, Seasoned QM loans. For QMs under the General QM loan definition in Section 1026.43(e)(2),
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