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#2255160 - 06/10/21 07:45 PM Re: QM rules under reconsideration John Burnett
Compliance504 Offline
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Joined: Dec 2008
Posts: 673
Tennessee
Thanks....that helps me a bunch!!!!

I don't know what I would do without BOL!!!

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Ability to Repay/Qualified Mortgage Rule
#2259724 - 09/15/21 02:21 PM Re: QM rules under reconsideration John Burnett
Dan Persfull Offline
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Dan Persfull
Joined: Aug 2002
Posts: 46,464
Bloomington, IN
https://home.treasury.gov/system/files/136/Freddie-Mac-Letter-Agreement-20210913.pdf

According to the letter to the GSEs the requirements in Sections 5.12(c), 5.13, 5.14(a) & (b) of the Agreement are the ones being suspended. I haven’t been able to find a copy of the actual agreement (which may not be a public document) so I’m not sure what is in those sections.

Can anyone help clarify what these suspensions may entail and will they have a possible impact on allowing the "Patch" to be reinstated for loans sold to the GSEs until October 2022?
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#2259735 - 09/15/21 03:05 PM Re: QM rules under reconsideration John Burnett
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 77,589
Galveston, TX
Not sure what impact that has if any. That agreement covers the dividend policy and liquidation of the GSEs and it has been amended at least three times and subject to at least one other letter agreement. The original agreement did not even include those Section numbers and I cannot locate the amended agreement in current form either.
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#2259744 - 09/15/21 04:41 PM Re: QM rules under reconsideration John Burnett
Dan Persfull Offline
10K Club
Dan Persfull
Joined: Aug 2002
Posts: 46,464
Bloomington, IN
Our President came up with the following;

https://www.fhfa.gov/Conservatorship/Pages/Senior-Preferred-Stock-Purchase-Agreements.aspx

As he said appears to be quite lengthy so it might be best to just wait to see if any guidance is put out by the agencies or banking organizations.
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The opinions expressed are mine and they are not to be taken as legal advice.

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#2259747 - 09/15/21 05:29 PM Re: QM rules under reconsideration John Burnett
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 77,589
Galveston, TX
Agreed - if you go through the original agreement, amendments and letter amendments, I still do not see Sections 5. 12(c), 5. 13, 5. 14(a), and 5. 14(b) of the Agreement, so I have no idea what that letter is referring too.
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#2261023 - 10/12/21 04:55 PM Re: QM rules under reconsideration John Burnett
Compliance504 Offline
Platinum Poster
Joined: Dec 2008
Posts: 673
Tennessee
Sold loans aside.....have most of you adopted using the new pricing based General QM rule over the old DTI General QM rule?

Do you think the CFPB is still considering making changes to the new pricing rule?

I'm not sure for retained loans whether or not to move forward with the new price based rules if they are going to change prior to Oct. 2022...

The way I understand the rules are now, we will not be able to determine if any loan is a Seasoned QM until March 1, 2024....and this could still change too.....but there is more time for that one.....

What have most of you been doing?

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#2263722 - 12/16/21 05:38 PM Re: QM rules under reconsideration Compliance504
ccman Offline
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Joined: Sep 2007
Posts: 900
Reviving this thread, has there been any updates from the bureau on the GSEs?

Need clarification again on the new QM rule: the rule is based on the spread of 2.25% or less to qualify as a QM all things aside. My
question is that based upon this spread, can a mortgage loan still be a QM but also be a HPML (first mortgage loan) as it exceeds the
1.50% APOR. Can someone clarify? Are you counting on the safe harbor to protect the bank and cover the risk?

Thanks.

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#2263736 - 12/16/21 07:54 PM Re: QM rules under reconsideration John Burnett
rlcarey Offline
10K Club
rlcarey
Joined: Jul 2001
Posts: 77,589
Galveston, TX
Can a mortgage loan still be a QM but also be a HPML?

Yes it can. I am not sure what there is to clarify. A QM is determined by 1026.43 and a HPML is determined by 1026.35. They are two separate tests.

I am not sure what this question means within this context: Are you counting on the safe harbor to protect the bank and cover the risk?
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