The Qualified Mortgage (QM) road has taken several twists and turns the last few months. To originate loans that qualify under the “new” general QM definition, you need:
- underwriting policies and procedures; and,
- to ensure file documentation reflects how your policies and procedures were applied in determining a consumer’s ability to repay.
The biggest challenge may be when it comes to underwriting exceptions.
Keep in mind, while the “new” general QM definition does not limit you to a specific debt ratio, your underwriting policies and procedures might (and likely do). Your policies and procedures also likely address the ability to make exceptions, including how and when exceptions can be made.
The “new” general QM definition provides some flexibility. However, your file documentation needs to be in line with your policies and procedures, and vice versa.
It’s easy to get confused, especially when dates keep moving! If you want to sort through what you need to know, join us on May 26,2021, for a 30 minute flash webinar on “The New General QM”.
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!