CFPB Flags Immigration Status as Potential Factor in Repayment Risk

Scotsman Guide spoke with Richard J. Andreano, Jr., who co-leads Ballard Spahr's Mortgage Banking Practice Group, about the CFPB's recently issued guidance cautioning that the immigration and residency status of borrowers could raise nonrepayment risks under existing mortgage lending rules.

"There is no industry standard in terms of assessing repayment ability in view of immigration status," Rich said. "It is not consistent with the CFPB policy to avoid issuing guidance except where necessary and where compliance burdens would be reduced rather than increased."

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