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CRL Comment to CFPB on Ability to Repay Standards under the Truth in Lending Act (Regulation Z)
CRL and allies comment on CFPB proposal that addresses two issues critical to the future of safe, sustainable, and affordable access to mortgage credit. First, it considers how to define compensation for the purpose of calculating the points and fees cap contained in the qualified mortgage definition. Second, it proposes a series of exemptions for specialized lending programs and financial institutions.
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