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.