On March 22, 2016, the CFPB issued an Interim Final Rule (the “IFR”) amending the ability-to-repay (“ATR”) and qualified mortgage (“QM”) provisions of Regulation Z. The IFR, which implements a portion of the Helping Expand Lending Practices in Rural Communities (“HELP”) Act, became effective on March 31, 2016.

Before the IFR became effective, certain special…