On May 9, 2014, the Department of Veterans Affairs (the “VA”) issued an interim final rule defining what constitutes a “qualified mortgage” (“QM”) for purposes of the loans it guarantees, insures, or originates. The VA stated that, to quell persistent uncertainty among lenders regarding the treatment of VA loans under the temporary QM definition established by the Consumer Financial Protection Bureau (“CFPB”), it was adopting a rule designating all VA loans as QMs and all VA loans other than a subset of VA streamlined refinancings as safe harbor QMs.
The following chart illustrates the QM status of VA loans...
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