- This topic has 1 reply, 2 voices, and was last updated 12 years, 1 month ago by .
-
Topic
-
I have reviewed the new finalized amendments to Regulatuion Z for small creditor portfolio loans and balloon payment QMs. The cross-referencing in this regulation is driving me nuts so I need to ensure I interpret the regulation revisions accurately. Our Bank would fall under the amended exemptions as a small creditor despite that we are in a MSA. The rule also increased the safe harbor QM to increase the APOR from 1.5% points to 3.5% points. We do not make HPML loans due to the escrow requirements–our Bank is not set up to escrow currently. Based on my interpretation, even if the APOR is increasing for the QM rule, we still would be required to escrow a loan if we went above the APOR of 1.5% points for a first-lien loan, correct? It seems to defeat the purpose.
- You must be logged in to reply to this topic.