On December 10th, the Consumer Financial Protection Bureau (CFPB) issued two final rules that make significant changes to Regulation Z's ability to repay requirements. With an effective date of July 1st, financial institutions need to start preparing now for these changes. First, the CFPB is changing the requirements for a loan to be classified as a Qualified Mortgage (QM). Going forward, a QM must meet the following four-part test:
- Pricing Test
- Product Test
- Points and Fees Test
- Underwriting Test
Second, the CFPB has established a new category of qualified mortgages, the Seasoned QM. Seasoned QM's must meet certain product, underwriting and performance requirements.
- QM pricing test (APR v APOR)
- QM product restrictions
- New underwriting standards in place of Appendix Q
- Product limitations for Seasoned QM's
- Performance requirements for Seasoned QM's
Who Should Attend?
Loan originators, loan processors, lending managers, compliance professionals and internal auditors would all benefit from the material covered during this webinar.
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