ATR & QM Policies and Procedures
When it comes to the Ability to Repay (ATR) rules and the Qualified Mortgage (QM) requirements, there are certain instances where written policies and procedures are required. For instance, if you make non-QM loans, you must still comply with the ATR requirements but you do not need written policies and procedures. Written policies and procedures are not required for those small creditors making portfolio QM or balloon QMs either. On the other hand, if you make seasoned QMs or general QMs, you must have written policies and procedures. Here’s the thing, even if you are you not required to maintain written policies and procedures in those few instances, we often recommend you do so. Not only does it help get all your lenders on the same page, but it also often helps with your fair lending compliance efforts.
Kevin explains more in the video.
2025/04/07
Kevin Edwards
Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them. Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).