The Consumer Financial Protection Bureau yesterday issued a revised small entity compliance guide for the ability-to-repay/qualified mortgage rule. The revisions reflect changes to the final rule issued on May 29 and July 10. The rule’s effective date remains Jan. 10, 2014.
The revisions cover exemptions to ATR regulations for certain creditors, loans and federal programs. They modify the points and fees calculation in the loan originator rule and the APR threshold for small creditor and balloon-payment QMs. The revisions also clarify what counts as a QM for loans made and held by small creditors, which creditors are eligible to issue balloon-payment QMs, how to determine QMs eligible for GSE purchase or guarantee and how to determine debt and income under the QM’s 43 percent debt-to-income limit.
Since this new guide does not contain any additional changes to the ATR or QM rules other than those previously issues in May and July, there are no substantive changes that will impact ABIA members.
Download the compliance guide.
ABIA has a established a QM Task Force to address ABIA-member concerns about the QM rule. Please contact Renee Galbraith to participate in ABIA’s Qualified Mortgage Task Force.