Topic
Ability-to-Repay Rule
64 published works
Consumer Finance Monitor
CFPB Issues Guidance on Consideration of Immigration Status Based on Ability to Repay Requirements Without Providing Sufficient Detail to Assist Creditors
By Richard J. Andreano, Jr., John L. Culhane, Jr.
When the CFPB and Department of Justice withdrew a joint statement on the consideration of immigration status under the Equal Credit Opportunity Act in January 2026, we pointed out that…
Miami Family Law Blog
Florida family law: finding of ability to pay in contempt proceedings
Posted by Nydia Streets of Streets Law in Florida Family Law ProcedureAn important finding in a contempt proceeding in a Florida family law case is the ability of the alleged…
Consumer Financial Services Review
CFPB Sues Mortgage Lender Under Ability-to-Repay Non-QM Rules
What constitutes a “reasonable” ability-to-repay determination when making a mortgage loan? Since the CFPB’s Ability-to-Repay rules became effective in 2014, the clearest answer to that question is that making a…
Consumer Financial Services Law Monitor
South Carolina Proposes Legislation to Impose Ability-to-Repay Analysis for Installment and Payday Loans
By Jason Cover, Taylor Gess, Caleb Rosenberg, Jeremy Sairsingh
On January 9, a group of five bi-partisan South Carolina Senators introduced Bill 910, which would, among other things, require persons (non-bank lenders) providing "consumer installment loans" or "deferred presentment…
Consumer Finance Monitor
CFPB issues proposed rule on PACE financing
By Richard J. Andreano, Jr., Loran Kilson
The Economic Growth, Regulatory Relief, and Consumer Protection Act (Act) directs the CFPB to prescribe Truth in Lending Act (TILA) ability-to-repay (ATR) rules for Property Assessed Clean Energy (PACE) financing.…
Philadelphia Criminal Defense Blog
PA Superior Court: Trial Court Must Hold Ability to Pay Hearing Before Finding Parolee in Violation
The Pennsylvania Superior Court has decided the case of Commonwealth v. Reed, finding that the trial court erred in sentencing the defendant to prison for violating parole by failing to…
Credit Chronometer
In a World Where Subprime Auto Lending Is Illegal
The deep voiced “In a world . . .” movie trailer narrator is no longer with us, but his legacy lives on, calling us to imagine the unthinkable as we…
Consumer Finance Monitor
CFPB proposes to delay mandatory compliance date for new general qualified mortgage
The CFPB has proposed to delay the mandatory compliance date for the new general qualified mortgage (QM) rule that amends the Regulation Z ability to repay/QM rule from July 1,…
Consumer Finance Monitor
CFPB Finalizes Ability to Repay/Qualified Mortgage Rules
The CFPB recently issued a final rule amending Regulation Z ability to repay rule/qualified mortgage (QM) requirements to replace the strict 43% debt-to-income (DTI) ratio basis for the general QM…
Consumer Finance Monitor
Community group files lawsuit in D.C. federal district court to restore CFPB payday loan rule ability-to-repay provisions
The National Association for Latino Community Asset Builders, represented by Public Citizen and the Center for Responsible Lending, filed a lawsuit against the CFPB in D.C. federal district court seeking…