Does the final rule require small banks to collect and report CRA data.?
My bank makes QM Balloon loans and one of my new loan officers is insisting he does not have to stay under the QM 43% Debt to Income cap. He does, doesn’t he?
Does the final rule only apply to national banks?
To be a Small Creditor QM, must the loan be made in a rural or under served area?
If credit is denied because of issues related to only one applicant, for example a charge-off, can we disclose that reason to both applicants, and do both applicants get an Adverse Action Notice?
Does the final rule retain the "one rating" concept from the proposal?
Can we make non-QM HPMLs, and if so, what do we need to watch out for?
Has there been a case where a lender tried so hard to assist minority applicants that it had a fair lending issue with majority applicants?
A recurring charge was processed on a credit card that was closed due to bankruptcy. It had originally been denied and then was allowed a few days later. Is this allowed per regulations?
What is the effective date of the final rule?