2018 Rural/Underserved Lists

The CFPB recently announced that the 2018 Rural and Underserved Counties Lists are now available.  Here’s a quick rundown of where BSA Training and Banking Regulations Compliance Consulting amy11 - 2018 Rural/Underserved Liststhese lists come into play.

 

  • Balloon Payment QM’s

One of the criteria used to determine whether you’re eligible to originate Balloon-Payment QM’s is that you originated at least one closed-end, consumer-purpose, first-lien loan secured by a dwelling located in a rural or underserved area during the prior calendar year.

 

If the application is taken before April 1st, you meet this requirement if you made such a loan in either of the prior two calendar years.

 

  • HPML Escrows

One of the criteria that must be met if you want to be exempt from the HPML escrow requirement is that you originated at least one closed-end, consumer-purpose, first-lien loan secured by a dwelling located in a rural or underserved area during the prior calendar year.

 

If the application is taken before April 1st, you meet this requirement if you made such a loan in either of the prior two calendar years.

 

  • HPML Appraisals

If you originate HPML’s and find yourself subject to the additional appraisal requirement (due to the timing of when the seller became the owner and the purchase price), you don’t have to worry about the additional appraisal if the property is located in a rural county.

 

You can also use the CFPB’s Rural and Underserved Areas Tool to determine whether a specific address is located in a rural or underserved area.

 

If you would like to learn more about Qualified Mortgage & Higher-Priced Mortgage Loan requirements, be sure to join us on April 24, 2018, for our Ability to Repay, QM, High Cost & Higher Priced Mortgage Loans webinar.

 

Published
2018/03/08
Amy Kudlacek

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