CreditSlips

The Bubble According to Todd

01/25/13

Todd Zywicki has a long blog post criticizing the CFPB's Qualified Mortgage (QM) rule and using it as a jumping-off point for a call to transform the CFPB's leadership from a single Director to a commission.

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NLRB and CFPB: Recess Appointments

01/25/13

The DC Circuit's decision in
Noel Canning v. NLRB invalidated an National Labor Relations Board ruling on the grounds that three of the NLRB's five members were not validly appointed, so the NLRB lacked the necessary quorum to act.  The DC Circuit's held on two separate grounds that the NLRB members were not validly appointed.

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Recess at the CFPB?

01/25/13

As
has been widely
reported , the D.C. Circuit
today ruled
unconstitutional the
president's power to make recess appointments. This is a good thing.

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Inside the Foreclosure Reviews

01/24/13

Yves Smith has a pair of damning posts about the OCC foreclosure reviews (part I and part II).

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Hardship and sacrifice, now at the Warwick Hotel

01/23/13

Periodically, I get emails from media relations firms on behalf of American Task Force Argentina, a somewhat hard-to-pin-down group organized, as best I can tell, to lobby the US government to pressure Argentina to pay holdouts like Elliott Associates.

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Many Young People Will Die in Debt, but Hopefully Not From Debt

01/23/13

I had a weird night’s sleep and then openned up my e-mail to find this headline from credit and collection news “Does The Consumer Bureau Harm Those It Claims to Protect? & Study Predicts Millions Will Die In Credit Card Red.” The immediate implication in my drowsy state was that the CFPB was somehow killing people. Wow.

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QM Impact on the Mortgage Market

01/14/13

The American Banker has a story (paywalled) about the impact of the QM rule on subprime lending. Subprime loans are unlikely to qualify for the full QM safe harbor because they are typically priced at more than 150 bps above prime. This means that subprime borrowers now have a possible foreclosure defense if they can show that the lender failed to properly account for their ability to repay.

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Who Owns the MBS Claims? AIG or the Fed?

01/14/13

Alison Frankel has a great column today on the fight going on between AIG and the NY Fed about who owns the securities fraud claims associated with the MBS that AIG sold to the NY Fed (or more precisely, its Maiden Lane SPV) as part of its bailout. 

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Usury Laws Are Dead. Long Live the New Usury Law. The CFPB's Ability to Repay Mortgage Rule

01/11/13

The CFPB has come out with its long awaited qualified
mortgage (QM) rulemaking under Title XIV of the Dodd-Frank Act.  The QM rulemaking is by far the most important
CFPB action to date and will play a crucial role in determining the shape of
the US housing finance market going forward. The QM rulemaking also rep

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