Federal Reserve’s Proposed Rule to Implement the Ability-to-Repay Requirements for Residential Mortgage Loans and its Impact on Lenders and RMBS Investors

June 27, 2011
The Board of Governors of the Federal Reserve System recently published a proposed rule concerning implementation of the ability-to-repay requirements imposed by the Dodd-Frank Act that would prohibit creditors from making mortgage loans without regard to the consumer’s repayment ability. This update examines the impact of the proposed rule on residential mortgage lenders and RMBS investors and addresses the key issues to consider for participants in the residential mortgage securitization market.