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?
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.
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.
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I can't herd the cats anymore, so I just set up the electric fences and let them fry when they stray out of bounds.