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A question we received from one of our CMG members:
The Reg Z HPML exemptions reference a QM as defined in 15 USC 1639c. The definition in 15 USC 1639c does not include the temporary QM for loans guaranteed by a federal program. Does that mean that QM status loans under the temporary QM are not excluded from the HPML requirements?
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The answer to your question is somewhat complicated but it boils down to if the loan meets the QM requirements then it is exempt from the HPML appraisal requirements. The commentary addresses this but I think the discussion in final rule explains it better. Take a look the final rule in the federal register: https://www.gpo.gov/fdsys/pkg/FR-2013-12-26/pdf/2013-30108.pdf, beginning on page 78527 with the information under the final rule – I think you’ll find all the details you need.
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