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We are doing a consumer credit transaction secured by a dwelling located on 65 acres. Because of the 65 acres the transaction is exempt from RESPA, would this loan also be exempt form the QM Rule? I’m thinking of the exemption of early disclosures under TIL if RESPA does not apply.
Whether or not a loan is covered by RESPA does not determine if the ATR/QM rules apply to the loan. You’ll look to the scope of 1026.43 to determine what transactions are covered. Typically a a consumer purpose, dwelling secured loan is covered unless one of the exemptions apply (Some exemptions include: HELOCs, loans secured by time share, reverse mortgage, temporary/bridge loans, construction phase of 12mths or less of constr./perm, and others you can find here: https://www.ecfr.gov/cgi-bin/text-idx?SID=c9cc74255c39fcc4f7169558a682f32d&node=12:9.0.1.1.1.5.1.13&rgn=div8).
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