CFPB Delays Mandatory Compliance Date for General QM Rule

Filed in Advocacy, Housing Finance by on April 28, 2021 0 Comments

qualified mortgage loan applicationThe Consumer Financial Protection Bureau (CFPB)  has formally delayed the mandatory compliance date of the General Qualified Mortgage (QM) final rule from July 1, 2021, to Oct. 1, 2022.

The agency said in a press release that it is taking this action “to help ensure access to responsible, affordable mortgage credit, and preserve flexibility for consumers affected by the COVID-19 pandemic and its economic effects.”

The General QM final rule would replace the current requirement for General QM loans that the consumer’s debt-to-income ratio (DTI) not exceed 43%, with a limit based on the loan’s pricing. In adopting a price-based approach to replace the specific DTI limit for General QM loans, the CFPB determined that a loan’s price is a strong indicator of a consumer’s ability to repay and is a more holistic and flexible measure of a consumer’s ability to repay than DTI alone. A loan meets the general QM definition if its annual percentage rate exceeds the average prime offer rate (APOR) for a comparable transaction by less than 2.25 percentage points.

In addition, the General QM final rule:

  • Provides higher pricing thresholds for loans with smaller loan amounts, for certain manufactured housing loans, and for subordinate-lien transactions.
  • Retains the General QM loan definition’s existing product-feature and underwriting requirements and limits on points and fees.
  • Requires lenders to consider a consumer’s DTI ratio or residual income, income or assets other than the value of the dwelling, and debts, and removes appendix Q and provides more flexible options for creditors to verify the consumer’s income or assets other than the value of the dwelling and the consumer’s debts for QM loans.

QM loans are presumed to be made based on the lender’s reasonable determination of the home owner’s ability to repay the loan.

Read the final rule.

Read an executive summary of the final rule.

For more information, contact Curtis Milton.

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