The purpose of Regulation Z’s Ability to Repay and Qualified Mortgage (QM) requirements are all about determining, to the best of your ability, whether the applicant(s) can pay back the loan. While there is a lot of criteria to meet and things to consider, it bears mentioning that it’s okay to make a loan that does not meet the QM standards. Non-QMs do not provide any kind of safe harbor, however. Loans that do meet QM status provide either a conclusive safe harbor or a rebuttable presumption of compliance safe harbor which can help you if the loan ends up in court later on.
Kevin explains these more in the video.
Published
2025/03/18