According to the statement, both the revised General QM and Seasoned QM rules will still go into effect on March 1st. However, it appears the CFPB plans to delay the July 1st mandatory compliance date for the General QM, as well as, the Temporary QM expiration date.
If this happens, there will be two versions of the General QM (current and revised), a Temporary QM and the new Seasoned QM. The other QMs will remain unchanged (small creditor, FHA, VA, etc.). The rules, as originally written, were going to have the biggest impact on secondary market lending. With yesterday’s curveball; however, our best guess is that secondary market loan underwriting will remain unchanged until the CFPB decides what to do next.
The CFPB plans to revisit parts of the revised General QM definition and seemingly the Seasoned QM option as a whole. If the CFPB does decide to change or revoke the Seasoned QM, it will also address what happens with applications received on or after March 1st, while the rule was in effect.
Join us on March 9th as we bring you the ins and outs and where we’re at with all these QM changes in plain English!
Diane joined Banker’s Compliance Consulting with over 10 years of compliance experience and over 15 years of experience within the financial industry. Diane is a Certified Regulatory Compliance Manager (CRCM) and has a Bachelor’s Degree in Sociology with a concentration in Criminal Justice. She is a graduate of the Schools of Banking Compliance School and has participated in various other training opportunities throughout her career. Diane understands firsthand the struggles banks face in building and maintaining successful compliance programs. Her experience and common sense approach to consumer compliance is a great asset to our clients.
Diane and her husband have two kids who keep them busy. She enjoys running and other sports and is a big Bugs Bunny fan! She’s a bit crazy in that she does enjoy reading some of these regulations and she’s a “crazy cat lady!” Her cat tales are hilarious!