The Consumer Financial Protection Bureau’s recent change to the definition of small creditor, while seemingly poised to make room for products outside the Qualified Mortgage boundaries, actually amounts to drops in the bucket in regards to non-Qualified Mortgage lending and is unlikely to facilitate the widespread use or securitization of non-QM products. To be recognized as a small creditor, an institution previously had to originate up to 500 loans annually. The bureau’s finalization of the rule now extends the definition to companies with fewer than $2 billion in assets that originate fewer than 2000 loans annually.
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Ari Karen is an experienced litigator and speaker who has focused his practice in representing financial institutions in both government investigations and litigation before state and federal trial and appellate courts nationwide. Mr. Karen’s practice is diverse, representing clients on matters concerning banking regulations, Dodd Frank financial reform laws, contractual disputes, employment and labor statutes, wage-hour class actions, employment discrimination and fair lending matters, whistleblower complaints and non-competition claims, among others.
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