[Anonymous]

We are a small bank that sells most of our mortgages on the secondary market. We qualify for the small credit exemption. My question is about the situation where the loans are sold in under three years: If they are sold in under 3 years, they would lose their (the loans–not us) small creditor QM status. Has anyone heard any information on how the secondary market will respond to this? Will our loans even be marketable at that point, if they lose their QM status? I recall something about a tempoary exception that loans sold on the secondary market would assume to be QMs (for two years??)

[rcooper]

Your loans may or may not be marketable if they lose their QM status – it will depend on what the investor requires. But in reality it will be most likely be more difficult to sell loans that are not QMs.

And you may be thinking about the temporary QM – Special Rules option. See page 31 of the CFPB’s ATR/QM Small Entity Compliance Guide linked here: https://files.consumerfinance.gov/f/201310_cfpb_atr-qm-small-entity_compliance-guide.pdf

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