Understanding and Implementing Qualified Mortgage Revisions

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WHAT

The Ability to Repay/Qualified Mortgage rules have always provided several options for compliance. Now one option is expiring, another option is undergoing major revisions, and a new option is being created. All financial institutions must make decisions on which options to adopt and how to implement the option(s) chosen.

In a final rule released on October 20, 2020 (the Extension Final Rule), the Consumer Financial Protection Bureau (CFPB) amended Regulation Z to replace the January 10, 2021 sunset date of the Temporary GSE QM loan definition with a provision stating that the Temporary GSE QM loan definition will be available only for covered transactions for which the creditor receives the consumer’s application before the mandatory compliance date of final amendments to the General QM loan definition in Regulation Z.

On December 10, 2020, the (CFPB) issued two final rules related to qualified mortgage (QM) loans. The first final rule, the General QM Rule, replaces the current requirement for General QM loans that the consumer’s debt-to-income ratio (DTI) not exceed 43 percent with a limit based on the loan’s pricing. The second final rule, reveals a new Seasoned QM.

The new and revised rules are effective on or about mid-February 2021, which is 60 days after the final rules are published in the Federal Register.

• Compliance with the revised General QM rule is mandatory on July 1, 2021 with optional compliance between the effective date and July 1, 2021 mandatory date.
• The existing Temporary GSE QM option expires on the effective date, and creditors using that option must select an alternative option by the effective date.
• The seasoned QM rule will apply to covered transactions for which creditors receive an application on or after the effective date. The CFPB concludes that 60 days will provide creditors and the secondary market adequate implementation time for this final rule, which adds a new QM definition but does not require creditors or other stakeholders to take any action if they do not intend to rely upon the new QM definition. The CFPB has decided not to apply the final rule to loans in existence prior to the effective date. Thus, this final rule applies to covered transactions for which creditors receive an application on or after the effective date.

WHY?

This two-hour program explains the changes resulting from the recent final rules that amend the qualified mortgage options contained in 12 CFR 1026.43.

TOPICS

Upon completion of this program participants understand:

• The revised General QM rule, including the:
  • Prohibition on loan features;
  • Underwriting requirements. The final rule:
    • Replaces the existing General QM loan definition with its 43 percent DTI limit with a price-based General QM loan definition.
    • Grants QM status only if the annual percentage rate (APR) exceeds the average prime offer rate (APOR) for a comparable transaction by less than 2.25 percentage points as of the date the interest rate is set.
    • Provides higher thresholds for loans with smaller loan amounts, for certain manufactured housing loans, and for subordinate-lien transactions.
    • Retains the existing product-feature and underwriting requirements and limits on points and fees.
    • Requires that the creditor consider the consumer’s current or reasonably expected income or assets other than the value of the dwelling (including any real property attached to the dwelling) that secures the loan, debt obligations, alimony, child support, and DTI ratio or residual income and verify the consumer’s current or reasonably expected income or assets other than the value of the dwelling (including any real property attached to the dwelling) that secures the loan and the consumer’s current debt obligations, alimony, and child support.
    • Removes Appendix Q.
    • Preserves the current threshold separating safe harbor from rebuttable presumption QMs, under which a loan is a safe harbor QM if its APR does not exceed APOR for a comparable transaction by 1.5 percentage points or more as of the date the interest rate is set (or by 3.5 percentage points or more for subordinate-lien transactions). and
  • Effective date.
• The new Seasoned QM rule:
  • The definition of a covered transaction;
  • Product Restrictions;
  • Points and fees limits;
  • Debt-to-income ratio;
  • The concept of the seasoning period;
  • Performance Requirements; and
  • Effective Date
• The elimination of the Temporary GSE QM rule.

WHO

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

*This program will start at 11:00 AM EST, 10:00 AM CST,  9:00 AM MST, or 8:00 AM PST

**Recording Available

This webinar will be recorded and sent to all registrants.  You will receive links to the recording following the program.  These recordings have unlimited viewings and are available for up to one year.

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