I was interpreting this to say that as long as we make one of the covered qualified mortgages the threshold would be higher.
4) Higher-priced covered transaction means a covered transaction with an annual percentage rate that exceeds the average prime offer rate for a comparable transaction as of the date the interest rate is set by 1.5 or more percentage points for a first-lien covered transaction, other than a qualified mortgage under paragraph (e)(5), (e)(6), or (f) of this section; by 3.5 or more percentage points for a first-lien covered transaction that is a qualified mortgage under paragraph (e)(5), (e)(6), or (f) of this section; or by 3.5 or more percentage points for a subordinate-lien covered transaction.
The Unofficial Redline of the General QM and Seasoned QM Final Rules on the CFPB site says this:
(4) Higher-priced covered transaction means a covered transaction with an annual
percentage rate that exceeds the average prime offer rate for a comparable transaction as of the
date the interest rate is set by 1.5 or more percentage points for a first-lien covered transaction,
other than a qualified mortgage under paragraph (e)(5), (e)(6), or (f) of this section; by 3.5 or
more percentage points for a first-lien covered transaction that is a qualified mortgage under
paragraph (e)(5), (e)(6), or (f) of this section; or by 3.5 or more percentage points for a
subordinate-lien covered transaction. For purposes of a qualified mortgage under paragraph
(e)(2) of this section, for a loan for which the interest rate may or will change within the first five
years after the date on which the first regular periodic payment will be due, the creditor must
determine the annual percentage rate for purposes of this paragraph (b)(4) by treating the
maximum interest rate that may apply during that five-year period as the interest rate for the
full term of the loan.
Am I misinterpreting this?