Does anyone know what date the 2017 QM points and fees limits are based on?
Is it applications taken in 2017, loans consummated in 2017, or something else? Most rules with specific dates utilize the application date, but I'm hesitant to assume it is application without being able to cite it.

Here are some articles detailing the change:
https://www.cfpbmonitor.com/2016/06/20/c...cts-2016-error/
https://www.federalregister.gov/document...hoepa-and-atrqm

Thanks!