Exception Tracking Spreadsheet (TicklerTrax™)
Downloaded by more than 1,000 bankers. Free Excel spreadsheet to help you track missing and expiring documents for credit and loans, deposits, trusts, and more. Visualize your exception data in interactive charts and graphs. Provided by bank technology vendor, AccuSystems. Download TicklerTrax for free.
CFPB reconsidering QM rules
The Bureau has released a statement [scheduled for Federal Register publication on 2/26/2021] on the mandatory compliance date of the General QM Final Rule and possible reconsideration of that rule and the Seasoned QM Final Rule.
The Bureau is considering whether to initiate a rulemaking to revisit the Seasoned QM Final Rule. If the Bureau decides to do so, it expects that it will consider in that rulemaking whether any potential final rule revoking or amending the Seasoned QM Final Rule should affect covered transactions for which an application was received during the period from March 1, 2021, until the effective date of such a final rule.
The Bureau also expects to issue shortly a proposed rule that would delay the July 1, 2021, mandatory compliance date of the General QM Final Rule. If such a proposed rule were finalized, creditors would be able to use either the current General QM loan definition or the revised General QM loan definition for applications received during the period from March 1, 2021, until the delayed mandatory compliance date. Furthermore, the Bureau anticipates that the Temporary GSE QM loan definition will remain in effect until the new mandatory compliance date, except that the Temporary GSE QM loan definition would expire with respect to a GSE if that GSE ceases to operate under conservatorship prior to the new mandatory compliance date.
The Bureau will consider at a later date whether to initiate another rulemaking to reconsider other aspects of the General QM Final Rule. Acting Director Dave Uelio discussed the two rules and the Bureau's plans in a Bureau Blog post yesterday.
The CFPB also posted an update of its small entity compliance guide for the ATR/QM rule, to include the latest amendments to the rule.