[jemery]

I haven’t been following the flood escrow changes very closely. I keep finding lots of updates and pieces of information. Is there one place I can find all of the requirements of flood escrow for 2016?

[jemery]

Vicar’s in Trouble, Jenni Emery, Beacon Credit Union, Group 2

[jemery]

I know there is no exemption for 25+ acres. However, for many agriculture loans the loan includes the primary residence, but the loan is considered to be for business purposes. So in this case, it would still be exempt from ATR/QM and Reg Z because it is a business purpose loan, correct?

[jemery]

I have been reading part of the regulation again trying to figure out if a loan is a non-QM and meets the ATR standards does it also need to comply with Appendix Q? From my interpretation of the regulation, my thoughts that only a QM loan needs to comply with Appendix Q. Is this correct?

[jemery]

Just to clarify on number one… So if I have a covered transaction we must either comply with the general ATR rules which are the 8 factors and covered in Appendix Q or we can comply with the QM rules and have a safe harbor/rebuttable presumption of compliance? So basically if we comply with the general ATR rules only we will have a non-QM loan?

[Author]

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