This is the fourth installment in a series of blogs covering the sessions I attended at this year’s American Banker’s Association (ABA) Regulatory Compliance Conference (RCC) in New Orleans.
Attendance for this session was mandatory because it was my session! I was privileged to be part of a great panel of compliance professionals that attempted to address some of the issues and hot spots related to the Ability to Repay (ATR) and Qualified Mortgage (QM) rules. These were some of the key points:
• ATR & QM – This is where compliance and credit meet. Collaboration is absolutely necessary to achieve both a compliant loan and safe & sound loan.
• Have you updated your loan policy/procedures?
• Policy and procedures exceptions – This is where your ATR/QM fair lending hot spots will reside. They MUST be monitored and controlled.
• ATR/QM record retention – Where’s the documentation? If you’re a HMDA bank, it’s different data but the idea is the same. Be prepared to prove your data! If you’re a HMDA bank you are already accustomed to doing this. In this case, the data is different but the process is the same.
• Monitoring ATR/QM – You need to audit, train, audit, train, audit, train and then audit and train some more.