Banker's Compliance Consulting Blog

Online Bankers Training - Qualified Mortgage (QM) Twists and Turns

Written by Diane Dean | May 17, 2021 3:05:03 PM

The Qualified Mortgage (QM) road has taken several twists and turns the last few months.  To originate loans that qualify under the “new” general QM definition, you need:

  1. underwriting policies and procedures; and,
  2. to ensure file documentation reflects how your policies and procedures were applied in determining a consumer’s ability to repay. 

The biggest challenge may be when it comes to underwriting exceptions. 

Keep in mind, while the “new” general QM definition does not limit you to a specific debt ratio, your underwriting policies and procedures might (and likely do).  Your policies and procedures also likely address the ability to make exceptions, including how and when exceptions can be made. 

The “new” general QM definition provides some flexibility.  However, your file documentation needs to be in line with your policies and procedures, and vice versa. 

It’s easy to get confused, especially when dates keep moving!  If you want to sort through what you need to know, join us on May 26,2021, for a 30 minute flash webinar on “The New General QM”.

Published
2021/04/17