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?
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?