Reply To: Is QM exepmt if RESPA doesn't 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: