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#2083965 - 06/17/16 03:42 PM QM coding in Core system
Vander Offline
100 Club
Vander
Joined: Jul 2003
Posts: 216
Texas
We decided to code the type of QM being originated in our core system to help when it came to exam time. All this time later, the result is that every covered loan we do is a QM of one kind or another. Has anyone had an exam where they asked for this type of information, a report. etc.? I can look at the loan file and tell you the kind of QM. Coding in the core system is just an extra step that I'm thinking is now unnecessary.

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Ability to Repay/Qualified Mortgage Rule
#2084113 - 06/17/16 09:03 PM Re: QM coding in Core system Vander
Always In Training Offline
Diamond Poster
Joined: Jul 2006
Posts: 1,115
Where the Green Grass Grows
We had the FDIC here in Feb/ March. They asked if we did QMs, and they asked me to prove our status as small/rural. All in the pre-exam packet. That was all. They didn't ask anything else. That being said, that doesn't mean that a different exam team or a lawyer, or an investor, even an industry survey later won't ask you to what kind you made.

I think you did a great thing! Changing systems or processes is HARD, so I salute your effort!

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#2084164 - 06/20/16 02:09 PM Re: QM coding in Core system Vander
Jen J Offline
100 Club
Joined: Dec 2015
Posts: 144
In the last exam I was part of (Federal Reserve), we were asked to provide a list of our qualified mortgages. We had decided as a bank to focus on ATR guidelines and not QMs, and as a result, we did not track qualified mortgages. I told the Federal Reserve that, and that was the last we heard about it. They tested our compliance with the ATR requirements and that was it.

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