Yes, see in the ATR rules below that it references the high cost mortgage points and fees test.
1026.43(e)(3): Limits on points and fees for qualified mortgages. (i) A covered transaction is not a qualified mortgage unless the transaction’s total points and fees, as defined in § 1026.32(b)(1), do not exceed…
And I haven’t heard anything on the CFPBs list of homeownership counselors. Let’s hope they have it available by the effective date of January 10th.