Reply To: Small Creditor Qualified Mortgages


If it is a HELOC they are not included. If it is a covered loan and it closes in your bank’s name then it should count towards the 500 since it was originated by your bank. Look at 1026.35(b)(2)(iii)(B)&(c).

1026.43(e)(5) Qualified mortgage defined—small creditor portfolio loans. (i) Notwithstanding paragraph (e)(2) of this section, a qualified mortgage is a covered transaction:

(A) That satisfies the requirements of paragraph (e)(2) of this section other than the requirements of paragraph (e)(2)(vi) and without regard to the standards in appendix Q to this part;