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#2028386 - 07/21/15 02:08 PM Small Creditor Exemption Extension
Skittles Online
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Skittles
Joined: Sep 2002
Posts: 13,965
TN
As of today the small creditor exemption will expire in January 2016. I know that it was proposed to extend to April 2016; however I haven't seen anything since. Since we do fixed rate 62 month balloon loans this is a very important topic here. Has anyone heard anything else about the extension - even during this busy TRID change?

Thanks!
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Ability to Repay/Qualified Mortgage Rule
#2028391 - 07/21/15 02:22 PM Re: Small Creditor Exemption Extension Skittles
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,219
Galveston, TX
Nothing yet. The CFPB did say this however:

Follow-up on other mortgage rules

We’re also continuing to work with stakeholders to address questions about rules we released in January 2013 to implement various Dodd-Frank Act mortgage reforms. Among other efforts, we’re issuing clarifications and amendments as warranted. For example, we’re working to finalize a proposal we published in February 2015 to modify certain requirements for small creditors, including those that operate predominantly in “rural or underserved” areas. We expect to issue a final rule in fall 2015.
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#2028417 - 07/21/15 02:58 PM Re: Small Creditor Exemption Extension Skittles
Skittles Online
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Skittles
Joined: Sep 2002
Posts: 13,965
TN
Thank you Randy. Unfortunately we're not in the 'rural or underserved areas'. We might have to go to ARM loans; however mgmt. isn't looking at anything yet.
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#2028433 - 07/21/15 03:46 PM Re: Small Creditor Exemption Extension Skittles
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,219
Galveston, TX
The extension of the balloon exception until April 2016 was included in this proposal.
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