ABA released a free strategic guide, available to bank members only, to help bank managers and directors evaluate potential responses to the recently finalized ability-to-repay and qualified mortgage rules.
The guide, which was produced in partnership with the Dechert LLP law firm, provides a legal framework for ATR implementation, summarizes the rules’ requirements and offers other strategic considerations.
“The ATR/QM rules change the mortgage landscape,” said ABA EVP Bob Davis, one of the report's authors. “They present bank managers and directors with a range of novel challenges and opportunities that each bank will have to evaluate.”
The guide suggests that “[m]anagement and directors will have to consider the corresponding profit, risk and legal implications of the different business options that are available in order to discharge their duties as overseers of the business of the bank."
Preparing to implement the new rules “will require the full attention and judgment of bank management and the board of directors,” the guide adds.
View the guide.
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