We are a small creditor making balloon loans under the exemption, we are expecting to have some of our old loans maturing and not being able to qualifiy under the ATR rules because of self employment, change in jobs, loss of income, etc. On refinances with no new fund how are other small creditors handling these loans? Also, if we have to finance the escrow premiums this will be new money how will you hanlde these?

We are doing our best to modify prior to maturity. There will be some that are fully refinanced anyway and it just is what it is...can't really be helped and we will not be opting for foreclosure unnecessarily.

Modifications on ones with no new funds.

If you have to advance money I think you will just have to document extremely well. The intent of the regs wasn't to make you foreclose on performing loans.

If we have to advance new funds the loan will not be a QM since it does not meet the ATR rules, are yall coding the non-QM loans on your system with a code to tract how many Non-QMs you have on your books?

Other way around for us - we're going to flag the QMs since we expect to have less of them than the non-QMs.

We have to mark within our platform system whether it is or isn't a QM.

We feel like all of our new originations will be ATR and QM qualified.

I don't see advancing new money on non-ATR-qualifiable refinances...I only see being able to do 'work-outs' to continue amortizing out the loan.