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Revisions to Regulation Z published by the Consumer Financial Protection Bureau on September 21, 2015 revised the Ability to Repay/Qualified Mortgage (ATR/QM) options available to all financial institutions. One of the existing options expires on April 1, 2016 and other options are revised effective January 1, 2016.
• How do the changes impact your institution?
• Are the ATR/QM options currently used by your institution still legally available?
• What previously excluded ATR/QM options may now be available to your institution?
• What changes to your compliance management system are needed to assure the continued success of your ATR/QM compliance program?
• What decisions may need to be made by your Senior Management/Board to determine how your financial institution will comply with these revisions?
You need to evaluate what options are still available and what options expire in 2016.
This two-hour webinar reviews all seven ATR options, including the five QM options. The new small creditor and rural and underserved areas rules are reviewed in detail with a discussion of the positive and negative impact these changes may have on your institution. In addition to reviewing the alternatives available to your institution the program also outlines the steps necessary to take advantage of the positive changes and lessen the impact of negative changes.
Upon completion of the program participants understand:
- The seven Ability to Repay Options and the five Qualified Mortgage Options;
- What conditions must be met for a loan to be considered under these options;
- When and why the Temporary Balloon Qualified Mortgage option expires;
- Which remaining ATR/QM options allow for balloon payment loans;
- Alternatives to balloon payments;
- What special ATR/QM options remain for small creditors;
- What institutions qualify as “small creditors” under the revised rules; and
- The expanded definition of “rural area” and how the change may impact your institution;
- How does the change impact your ATR/QM options;
- What tools are available from the Census Bureau and the CFPB to determine which areas are rural areas and how to use those tools; and
- The impact, positive or negative, these changes may have on your institution and how to manage those changes to improve your compliance system.
This informative session will benefit auditors, compliance officers, loan officers, loan processors and other personnel with mortgage lending responsibilities.