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Ability to Repay/Qualified Mortgages Review and Update, Webinar
October 20, 2021 @ 1:30 pm - 3:30 pm CDT
- The revised General QM rule, including the:
- Prohibition on loan features;
- Underwriting requirements. The final rule:
- Replaces the existing General QM loan definition with its 43 percent DTI limit with a price-based General QM loan definition.
- Grants QM status only if the annual percentage rate (APR) exceeds the average prime offer rate (APOR) for a comparable transaction by less than 2.25 percentage points as of the date the interest rate is set.
- Provides higher thresholds for loans with smaller loan amounts, for certain manufactured housing loans, and for subordinate-lien transactions.
- Retains the existing product-feature and underwriting requirements and limits on points and fees.
- Requires that the creditor consider the consumer’s current or reasonably expected income or assets other than the value of the dwelling (including any real property attached to the dwelling) that secures the loan, debt obligations, alimony, child support, and DTI ratio or residual income and verify the consumer’s current or reasonably expected income or assets other than the value of the dwelling (including any real property attached to the dwelling) that secures the loan and the consumer’s current debt obligations, alimony, and child support.
- Removes appendix Q.
- Preserves the current threshold separating safe harbor from rebuttable presumption QMs, under which a loan is a safe harbor QM if its APR does not exceed APOR for a comparable transaction by 1.5 percentage points or more as of the date the interest rate is set (or by 3.5 percentage points or more for subordinate-lien transactions). and
- Effective date.
- The new Seasoned QM rule:
- The definition of a covered transaction;
- Product Restrictions;
- Points and fees limits;
- Debt-to-income ratio;
- The concept of the seasoning period;
- Performance Requirements; and
- Effective Date
- The elimination of the Temporary GSE QM rule.
Who Should Attend?
The program is designed for Compliance Officers, Loan Officers, Loan Processors, Auditors, and others with responsibilities related to the origination and servicing of mortgage loans.