I've found that after...

1.) Attending Jack H.'s course
2.) Reading the Summary
3.) Reading Appendix Q
4.) Referencing certain parts of the full rule

...I now have a solid understanding of how this will apply to my shop. Basically, figure out what loans you/senior management are willing to do without the safe harbor (based on your shops relationship with customers/size/underwriting criteria/risk profile) and what you would prefer to do as a QM. After that, talk with your credit department. Make sure they are onboard with knowing that they need to use Appendix Q for a QM and that staff will need to collect third party verifications for income/employment/etc. If you are a solid lender, the reality is that you are probably doing a pretty good job of analyzing income/DTI already.

Overall, figure out how this rule applies to your situation. After that, stop killing yourself with semantics.

If your operation is residential mortgage intensive, this may be tougher, but it can still be done if you focus on your operation and the implications of ATR and QM.

I'm going to have a celebratory beer for having figured this out and getting management on board.

I just got thru with the summary and actually, i agree. No problems with the summary.

The CFPB has updated the guide to reflect the 10/1/13 rule changes. http://files.consumerfinance.gov/f/201310_cfpb_atr-qm-small-entity_compliance-guide.pdf

To clarify a point made earlier -- a small creditor does not have to meet R/U qualifications to make balloon QMs under the Temporary Balloon Payment QM provision in .43(e)(6).