Getting it Right: Ability-to-Repay and Qualified Mortgages in 2024

March 7, 2024



It can be tempting to adopt a “if it ain’t broke, don’t fix it” mentality. However, that can lead to old processes maturing into unexamined, in-stone procedures that may no longer serve their purpose effectively or efficiently. That is when non-compliance can creep in.

We’ve found at the Ability to Repay and Qualified Mortgage Rule, which is now over a decade old, is a commonly overlooked area that leaves financial institutions open to risk. Join us March 7th to take a fresh look at the ATR/QM rule and develop an efficient plan for compliance.

We’ll examine:

  • 2022’s revised general QM rule and whether your FI adjusted to the changes adequately.
  • How to evaluate consumer mortgage loans in your institution’s portfolio from an ATR/QM perspective.
  • How to qualify customers in a rising-rate environment.
  • Making higher priced mortgage loans (HPMLs), as well as how these are distinct from HPCTs and HCMLs.
  • Making manufactured-home loans, with or without land.
  • How to deal with Small Creditor Escrow Exemption claims
  • Making balloon loans.
  • How ATR/QM should be handled by “small creditors” and “rural/underserved” lenders.
  • The types of legal protections available, loan feature limitations and restrictions, and underwriting requirements.


When the revised General QM rule became mandatory in October 2022, important changes kicked in that completely transformed old legacy QMs.  Do you know precisely what they are and how they affect your financial institution? Were the changes a good thing for your shop?  Maybe it would be better for you to pursue “Seasoned QMs” or perhaps the “Statutory QM” (aka the biggest sleeper provision out there). The Small Creditor QM is still alive and well, as is the Balloon QM, along with the good old baseline ATR “non-QM”.

There are so many types of QM and finding the right one for your bank is an important consideration. By confidently understanding what QM status vs Non-QM status brings to the table, you can bring value and relevant risk-management insight to senior management.

Everything needs a checkup, and the Ability-to-Repay / Qualified Mortgage rule is no exception.  Why are you doing what you are doing?  Is it still appropriate, and what is the best approach for compliance in your bank?  The rules have changed – some of them significantly – and some verdicts have literally passed on the matter. So join us to take a fresh look at the ATR / QM rule and gain new perspectives on it.


This session is designed for Compliance Officers, Loan Officers, Loan Processors, Auditors, and others with responsibilities related to the origination and servicing of mortgage loans.


Rebekah Leonard

Rebekah F Leonard, CRCM Rebekah is the owner of Elucidate LLC, a compliance training and consulting company.  Elucidate means to “make clear, explain, throw light upon”, and describes Rebekah’s desire to illuminate the complexities of compliance with passion and fun.  She’s created and produced a TRID music video parody and several Compliance Breakout escape rooms, which she frequently provides at state banking compliance conferences.  She is an accomplished speaker and regularly provides webinars through BOL and Compliance Resource.

Rebekah is currently serving as the VP Director of Compliance for a $6 Billion community bank in Montana.  She began her career in 1995 at a private lending company, but soon settled into banking, where she’s covered nearly all of it – customer service and teller work, loan processing and review, and security and business continuity.  She now oversees CRA, BSA and all aspects of compliance as a senior leader.  She has successfully navigated numerous FDIC Compliance, CRA, and BSA Exams.

Rebekah has a bachelor’s degree in Organizational Leadership from Chapman University (Magna cum Laude), attended the American Bankers Association National Compliance School in 2003, and has held her Certified Regulatory Compliance Manager designation since 2006.  She is a BOL Compliance Guru.

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Price: $0.00
Start Time: 2:00 pm EST
End Time: 4:00 pm EST

March 7, 2024

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