With regard to the small-creditor category of “originated 500 or fewer first-lien covered transactions during the previous calendar year.” As this begins in January 2014, does this mean we should count 2012 loans or 2013 loans for determining the 500 threshold for small-creditor status for 2014 originations in January?

Good question Compliance Poster. I would hope we would use 2012, as the change takes affect January 10, 2014. Of course, with the CFPB, we never know.

We have interepreted it as 2013. The commentary states if you want to make loans under the small creditor QM provisions in 2014, you must qualify by making 500 or fewer first lien covered transactions in the preceding calendar year. I take that to mean 2013. Hopefully someone will jump in if I am incorrect.

I agree with you Bullseye.

Thanks!

Just because it's nice to sing harmony once in a while, I'll add my support for counting your 2013 activity.