American Bankers Association Real Estate Lending Conference - Qualified Mortgages: A Sea Change For Mortgage Lenders


In This Presentation:

- The Qualified Mortgage (QM) Rule

- Small Creditor QM Proposal

- The Ability-to-Repay (ATR) Rule: What It Says and What It Means

- Liability for Failure to Comply with the ATR and QM Rules

- Legal Implications for Non-QM Loans

- Legal Implications for QM Rebuttable Presumption Loans

- Legal Implications of QM Safe Harbor Loans

- The New World of Fair Lending Seen Through the ATR Prism

- Fair Lending Issues Related to New Rules

- Disparate Impact Developments

- CFPB & HUD View of Fair Lending

- Other Fair Lending Developments

- Issues Under the New Rules

- ATR and the Mortgage Securitization Market Response

- Securitization Issues

- Risk Retention Proposal

- QRM Exception

- Excerpt from QRM Exception:

• Qualified Residential Mortgage (QRM) Exception

– QRM exception allows securitizer to avoid risk retention requirement

– To be issued by FRB, OCC, FDIC, SEC, HUD and the FHFA

– QRM exception cannot be any broader than the Bureau’s QM standards

– Agencies had been waiting for QM rule to be issued to issue a final risk retention rule that takes account of the Bureau’s rule.

Please see full presentation below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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