Ah, this is a fascinating one! The Economic Growth, Regulatory Relief, and Consumer Protection Act of 2018 created the mother of all sleeper provisions when it changed the Truth in Lending Act to include a special little Qualified Mortgage. Since then, it has gotten very little attention, and the CFPB officially washed its hands of it in their latest QM revisions. But it is alive and well, and available for any bank (under $10 Billion in assets, counting affiliates) that wants to take advantage. There are very few qualifying requirements (holding it on your books is the main one), but otherwise it is a wild child that could bring QM status to many of your mortgage loans, including balloons!
Surprised? Learn more about the EGRRCPA QM at the upcoming webinar “Taking a Fresh Look at Qualified Mortgages and the Ability-To-Repay Rule” on February 15, 2023!
Learn more about Rebekah Leonard’s Taking a Fresh Look at Qualified Mortgages and the Ability-To-Repay Rule webinar.