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#2173593 - 04/16/18 01:56 PM Can a high cost loan be a QM?
Compliance NABW Offline
Diamond Poster

Registered: 10/22/15
Posts: 1131
I always had it in my mind that a Section 32 loan could not be a QM. But, after needing to research further, I am not so sure anymore. Obviously, the points and fees trigger would be a no go, so to speak, as would the prepayment penalty, but if the only thing making the loan a Section 32 transaction is the APR/APOR rate spread, could it still be a rebuttable presumption QM? This would be assuming they showed the correct ability-to-repay, etc. at the high interest rate. I am not coming across any piece of the Regulation that prohibits this.

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Ability to Repay/Qualified Mortgage Rule
#2173595 - 04/16/18 02:01 PM Re: Can a high cost loan be a QM? [Re: Compliance NABW]
raitchjay Offline
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Registered: 10/15/09
Posts: 7721
Loc: OK
previous thread

I found this...might help.
_________________________
I'm fixin' to fix that.

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#2173722 - 04/16/18 08:14 PM Re: Can a high cost loan be a QM? [Re: Compliance NABW]
Compliance NABW Offline
Diamond Poster

Registered: 10/22/15
Posts: 1131
Thank you. So, it sounds like it can very well be if the only trigger for the Section 32 is the APR/APOR spread.

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