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?
What questions do loan portfolio metrics help to answer?
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?