Reply To: ATR/QM


These minimum standard requirements for dwelling secured loans (that have been labeled ability-to-repay rules) apply to any consumer credit transaction secured by a dwelling with the exception of HELOCs, loans secured by time-shares; and reverse mortgages, temporary or bridge loans of 12 months or less, a construction phase 12 months or less of a construction-to-perm loan and a few other types of loans made under certain programs/guidelines are exempt from most of the requirements (with the exception of the rules pertaining to prepayment penalties and evasion). Take a look at 1026.43 to get a full list of what is covered/excluded from these requirements. Here’s a link to the regulation:

For any covered loan you need to comply with the general ability-to-repay rule or one of the QM rules. You can choose which to comply with on a case by case basis.

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