by: Alex Radetsky & Carlos Larkin
On March 29, 2011, the Office of the Comptroller of the Currency (“OCC’), the Board of Governors of the Federal Reserve System (“FRB”), the Federal Deposit Insurance Corporation (“FDIC”), the U.S. Securities and Exchange Commission (“SEC”), the Federal Housing Finance Agency (“FHFA”), and the Department of Housing and Urban Development (“HUD”) jointly issued a proposed rule to implement Section 941(b) of the Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Proposed Rule”). Althought this rule is extenstive, this post will be limited to a discussion of Qualified Residential Mortgages (“QRMs”), their exempt status and the underwriting standards that create this exemption.
