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Bradley Arant Boult Cummings LLP 

February, 2021 - Birmingham, Alabama



Bradley Partner Jonathan Kolodziej Quoted in Inside Mortgage Finance on the Effective Date of the New QM Rule



Bradley attorney Jonathan Kolodziej was quoted in Inside Mortgage Finance on when the new qualified-mortgage (QM) standards will go into effect. In December, the CFPB issued two final rules for QMs that are scheduled to go into effect on March 1. However, the acting CFPB director announced the bureau is "exploring options to preserve the status quo" with respect to qualified mortgages, which has led some to believe the CFPB will delay the effective date.

Kolodziej said the most likely scenario is the CFPB extends the effective date so there is time to consider whether the new administration wants to make changes. He said this happened with the "small dollar rule" when Director Kathy Kraninger took over the CFPB. 

Moreover, Kolodziej said extending the effective date is "more aligned" with the White House memo on the regulatory freeze, which allows an agency to open a 30-day comment period for any rule that hasn't yet been implemented than "preserving the status quo" by revoking the rulemakings entirely. 

The original article, "Is March 1 Still the Effective Date of the New QM Rule?" appeared in Inside Mortgage Finance on February 16, 2021. 


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