Hello, I'm wondering how construction to permanent loans with a single closing should be treated under the GSE's new General QM price-based threshold test.
For ARM loans, we must use the highest interest rate that'll be in effect during the first five years. However, it seems that this will basically always automatically disqualify ARM loans from General QM classification since the APR will exceed the APOR by more than 2.25%.
Are construction loans somehow exempt from the new General QM price-based threshold test? Thanks.