Executive Letter: Regulation Z Ability To Repay: Revised General QM Loan Definition Toolkit

By Rose Oswald Poels

As many of you may already know, I began my career as an attorney on WBA’s legal team over 30 years ago. Lightening the burden of ever-changing regulations on member banks is a priority of the association that I continue to have a keen appreciation for in my role as president and CEO.

In addition to our Legal Call Program, WBA works to provide members with resources including articles, training events, and webinars to help you to stay compliant with regulations and perform your work efficiently.

The latest resource WBA’s legal team has compiled is the Regulation Z Ability to Repay: Revised General QM Loan Definition Toolkit, which is designed for use by financial institutions in understanding the 2020-2021 revisions to the Regulation Z general qualified mortgage (QM) definition. WBA aims to provide readers with a perspective of the rule change in relation to their operation, and prepare for implementation of revised loan policy and underwriting procedures, both in terms of practical and compliance considerations.

The toolkit serves as a template for banks to customize to their specific situation prior to its implementation and use.

As always, WBA is here to support our members with regulatory compliance, so you are able to dedicate more of your focus directly to serving your customers and communities.