District Circular Letters
July 29, 2014
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Application of Regulation Z’s Ability-to-Repay Rule to Certain Situations Involving Successors-in-Interest
On July 11, 2014, the Consumer Financial Protection (CFPB) issued an interpretive rule to clarify that where a successor-in-interest (successor) who has previously acquired title to a dwelling agrees to be added as obligor or substituted for the existing obligor on a consumer credit transaction secured by that dwelling, the creditor’s written acknowledgement of the successor as obligor is not subject to the Ability-to-Repay Rule (ATR Rule).
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