My financial institution is less than $2 billion. We originated fewer than 2,000 covered transactions. We do not serve any rural or underserved designated areas.

Do we qualify to originate small creditor QMs?

Yes

As Randy said, yes, you can qualify for the small creditor QM if you are 1) less than $2 billion and 2) originate fewer than 2,000 covered loans. The originations in rural/underserved designations apply for the balloon loan QM.

This small creditor qualification flowchart might help provide further clarification for you: https://files.consumerfinance.gov/f/documents/201603_cfpb_smallcreditorflowchart_final.pdf

Thank you both. What was confusing me is the CFPB has a flow chart that still references the 500 originated loans. We wouldn't qualify based on that. Thanks again.

Adam....I didn't check your link before responding. That's an update to the one I found. Thank you again.

Just remember to count both your institution and its affiliates (if any) in that 2,000 count and $2 billion (now $2.230 billion) limit.

John, thanks for the reminder on the affiliate amount and the inflation adjustments. For future reference, the inflation adjustments can be found here: https://www.consumerfinance.gov/rul...justment-asset-size-exemption-threshold/