ATR/QM/HCM/HPML Confusion

Confused on the Ability to Repay (ATR)/Qualified Mortgage (QM) Rule and its impact on the Higher-Priced Mortgage Loan (HPML) requirements?  Remember that some QM’s have special rate thresholds:

A Small Creditor Portfolio QM or Balloon Payment QM isn’t a higher-priced covered transaction (HPCT) unless it exceeds the Average Prime Offer Rate (APOR) by 3.5% or more, first liens included.  This means, rather than having a safe harbor for compliance, you have a rebuttable presumption of compliance.  However, first-lien Small Creditor Portfolio QMs and Balloon-Payment QMs with an APOR rate spread of 1.5 or more must still follow the HPML escrow requirements, (unless you’re exempt from them).  While QMs are exempt from the HPML appraisal requirements, don’t forget about the Regulation B appraisal requirements!  And don’t forget, if you have a non-QM HPCT, you must consider any balloon payment in the repayment analysis, regardless of when it occurs.

Still confused? Join us for our Ability to Repay (ATR), Qualified Mortgage (QM), High Cost Mortgage (HCM) and Higher-Priced Mortgage Loan (HPML) webinar on April 26, 2017.  We will dive right into the What, Where, When and How with plain English instruction and answers.

Register Today!

Published
2017/04/19
Deb Irving
David Dickinson

David Dickinson

David’s banking career began as a field examiner for the FDIC in 1990. He later became a Compliance Officer and Loan Officer for a small bank. In 1993, he established Banker’s Compliance Consulting. Along with his amazingly talented Team, he has written numerous compliance articles for prestigious banking publications and has developed compliance seminars that Banker’s Compliance Consulting produces.

He is an expert in compliance regulations. He is also a motivational speaker and innovative educator. His quick wit and sense of humor transforms the usually tiring topic of compliance into an enjoyable educational experience. David is on the faculty of the American Bankers Association National Compliance Schools and has served on the faculty of the Center for Financial Training for many years. He also is a frequent speaker at the ABA’s Regulatory Compliance Conference. He is also a trainer for hundreds of webinars, is a Certified Regulatory Compliance Manager (CRCM) and has been a BankersOnline Guru for many years. The American Bankers Association honored David with their Distinguished Service Award in 2016.

David and his wife Karen have three adult children, four grandchildren (none of whom live at home!) and two cats (of which Dave is allergic … the cats, not the children!). They recently moved to an acreage outside of Lincoln, Nebraska where he gets to play with his tractor. When possible David can be found fishing, making sawdust in his shop, or playing the guitar and piano. He also enjoys leading worship at his church.

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