Federal agencies have released a revised Risk Retention Proposal, which includes a revised definition of a Qualified Residential Mortgage (QRM).
Under the proposal, a QRM would meet the same criteria as a Qualified Mortgage (“QM”) under Regulation Z. This would exempt QM’s from the risk retention requirements.
Comments are due by October 30, 2013. Among the items the Agencies are seeking comment on is an alternative QRM definition (“QM-plus”). Such an approach would start with the QM criteria and add additional requirements related to occupancy, lien status, credit history, and loan to value. This approach would likely result in significantly fewer QRM loans.
We’ll be following the progress of this proposal and let you know of necessary updates as we become aware of them.
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!