On December 10th, the Consumer Financial Protection Bureau (CFPB) issued two final rules that make significant changes to Regulation Z's ability to repay requirements. With an effective date of July 1st, financial institutions need to start preparing now for these changes. First, the CFPB is changing the requirements for a loan to be classified as a Qualified Mortgage (QM). Going forward, a QM must meet the following four-part test:
- Pricing Test
- Product Test
- Points and Fees Test
- Underwriting Test
Second, the CFPB has established a new category of qualified mortgages, the Seasoned QM. Seasoned QM's must meet certain product, underwriting and performance requirements.
- QM pricing test (APR v APOR)
- QM product restrictions
- New underwriting standards in place of Appendix Q
- Product limitations for Seasoned QM's
- Performance requirements for Seasoned QM's
Who Should Attend?
Loan originators, loan processors, lending managers, compliance professionals and internal auditors would all benefit from the material covered during this webinar.
Carl Pry is a Certified Regulatory Compliance Manager (CRCM) and Certified Risk Professional (CRP) who is a Managing Director for Treliant Risk Advisors in Washington, DC. Through his working career, as well as through his experience as a banking attorney and officer, he has provided a variety of regulatory compliance and financial performance services to financial institutions and other clients throughout the country. He has written extensively regarding consumer and commercial compliance, tax, audit, and financial institution legal issues, and is a frequent contributor to and currently serves on the Editorial Advisory Board for the ABA Bank Compliance magazine. He has spoken at scores of banking, compliance, and state bar associations, and has conducted training sessions for financial institutions across the country.
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