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Small Creditor under QM

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  • #3494
    vstull
    Member

    I understand there is an exception for certain requirements under the QM rules. One of the requirements is the bank and “affiliates” originated 500 or fewer covered transactions. However, I am unable to find a definition in any of the new requirements of “affiliate” for the purposes of this exemption.

    Any guidance would be greatly appreciated.

    #3498
    rcooper
    Keymaster

    I don’t find a definition or reference to an another Regulation’s definition of affiliate for this section. The CFPB’s Regulation P and X, as well as the FRB’s Regulation W have definitions of affiliate that are very similar and, IMO, commonly accepted to define affiliate.

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