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#1988655 - 01/14/15 05:51 PM TILA 2015 Threshold
Cheli Offline
Platinum Poster
Cheli
Joined: May 2013
Posts: 919
Good afternoon,

My employer's software servicing company states that the 2015 TILA Threshold for the QM points and fees test is driven by application date. I was under the impression that the threshold would be for the consummation date...? To me that would make sense, as we are calculating the total loan amount to the amount financed etc...

Any thoughts? Expert opinion?

Thank you...

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Lending Compliance
#1988859 - 01/15/15 03:02 PM Re: TILA 2015 Threshold Cheli
Dan Persfull Online
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 47,517
Bloomington, IN
1026.43(e)

(3) Limits on points and fees for qualified mortgages. (i) Except as provided in paragraph (e)(3)(iii) of this section, a covered transaction is not a qualified mortgage unless the transaction's total points and fees, as defined in ยง 1026.32(b)(1), do not exceed:


1026.32

(b) Definitions. For purposes of this subpart, the following definitions apply:

(1) In connection with a closed-end credit transaction, points and fees means the following fees or charges that are known at or before consummation:
_________________________
The opinions expressed are mine and they are not to be taken as legal advice.

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#1988998 - 01/15/15 05:35 PM Re: TILA 2015 Threshold Cheli
Cheli Offline
Platinum Poster
Cheli
Joined: May 2013
Posts: 919
Thank you, Dan...That is what I thought as I read that too, and wanted to make sure I wasn't misinterpreting or missing any other information all together. I am still going rounds with them.

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