UDAAP May Interfere With 'Ability-To-Repay' Under TILA
May 9, 2012, 1:09 PM EDT
Law360, New York (May 9, 2012, 1:09 PM EDT) -- A lender’s obligation to consider and verify a borrower’s ability to repay a home mortgage loan is once again at the center of attention, currently resulting from the Consumer Financial Protection Bureau’s open comment period for a proposed regulation that will define which loan products are considered “qualified mortgage(s)” under the Dodd-Frank Act’s “ability-to-repay” amendment to the Truth In Lending Act (“TILA”).
The “ability-to-repay” amendment states that “no creditor may make a residential mortgage loan unless the creditor makes a reasonable and good faith determination based...
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