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The Ability to Repay/Qualified Mortgage (ATR/QM) rules were originally released in 2014. The Consumer Financial Protection Bureau (CFPB) revised the rules on September 21, 2015, January 1, 2016, and on April 1, 2016. Now Congress has jumped back in the game.
- Section 101 of the Economic Growth, Regulatory Relief and Consumer Protection Act (EGRRCPA) creates a new QM standard for small institutions (less than $10 billion in assets) that hold the loans in their portfolio and meet certain other criteria.
- Section 307 of the EGRRCPA orders the CFPB to develop ATR standards for property accessed clean energy (PACE) financing.
The President signed EGRRCPA on May 24, 2018. The provisions mentioned above were effective upon enactment, but the CFPB will revise the ATR/QM rules contain in §1026. 43 of Regulation Z.
So where does this history of change leave your institution?
- Have you evaluated the impact these changes may have on your institution?
- Are the ATR/QM options currently used by your institution still acceptable?
- How do you update your compliance management system to assure the continued success of your ATR/QM compliance program?
The ATR/QM rules have been in use for four years. During that four-year span the rules have been rocked by constant change. This two-hour webinar recording provides a comprehensive review of all the ATR options, including the existing and new QM options. The new EGRRCPA rules receive special attention. This webinar recording helps you decide whether changes are needed or if the status quo is acceptable.
Upon completion of the program participants understand:
- Which loans are covered by and which loans are exempt from the ATR/QM rules;
- The seven Ability to Repay Options and the five Qualified Mortgage Options;
- What conditions must be met for a loan to be considered under each option;
- When is a transaction considered a Higher Priced Covered Transaction and how that impacts Qualified Mortgage status;
- The options available for lenders using balloon financing;
- What institutions qualify as “small creditors” under the revised rules;
- What special ATR/QM options are available for small creditors, including the option presented by Section 101 of EGRRCPA;
- The expanded definition of “rural area” and how the change impacts your institution;
- How to consider PACE financing when evaluating the ability to repay; and
- What tools are available from the Census Bureau and the CFPB to determine which areas are rural areas and how to use those tools.
This informative session will benefit auditors, compliance officers, loan officers, loan processors and other personnel with mortgage lending responsibilities.
Jack Holzknecht is the CEO of Compliance Resource, LLC. He has been delivering the word on lending compliance for 43 years. In 38 years as a trainer over 145,000 bankers (and many examiners) have participated in Jack’s live seminars and webinars. Jack’s career began in 1976 as a federal bank examiner. He later headed the product and education divisions of a regional consulting company. There he developed loan and deposit form systems and software. He also developed and presented training programs to bankers in 43 states. Jack has been an instructor at compliance schools presented by a number of state bankers associations. As a contractor he developed and delivered compliance training for the FDIC for ten years. He is a Certified Regulatory Compliance Manager and a member of the National Speakers Association.