Ability-to-Repay/Qualified Mortgage Review and Update

WHAT? While the ATR/QM Rules were released in 2014, revisions to Regulation Z published by the Consumer Financial Protection Bureau on September 21, 2015 revised the Ability to Repay/Qualified Mortgage (ATR/QM) options available to all financial institutions. One of the qualified mortgage options expired on April 1, 2016, and other options were revised effective January 1, 2016.

  • Did you evaluate to determine how these changes impacted your institution?
  • Are the ATR/QM options currently used by your institution still legally available?
  • Are there previously excluded ATR/QM options now available to your institution?
  • How do you update your compliance management system to assure the continued success of your ATR/QM compliance program?

WHY? The ATR/QM rules have been in use for three years. Some of the rules were revised effective January 1, 2016, impacting the ATR/QM options available to financial institutions. Have you evaluated your financial institution’s process for proving ability-to-repay? Are the current options used by your institution to determine if the mortgage is qualified still available?

We will review all six ATR options, including the four QM options, and the option that expired during 2016. The new small creditor and rural and underserved area rules will be reviewed in detail, with a discussion of the positive and negative impact these changes may have had on your institution. In addition, the program will outline how to determine which areas are considered rural or underserved, and what tools are available to take advantage of the safe harbor for determining this status.

Covered Topics:

  • The scope and coverage rules for Ability to Repay
  • The exclusions allowed under the Ability to Repay rules
  • The six Ability to Repay Options and the four Qualified Mortgage Options
    • What conditions must be met for a loan to be considered under these options
    • When is a transaction considered a Higher Priced Covered Transaction and does that impact Qualified Mortgage status
  • When and why the Temporary Balloon Qualified Mortgage option expired
  • Which remaining ATR/QM options allow for balloon payment loans
  • What institutions qualify as "small creditors" under the revised rules
    • What special ATR/QM options remain for small creditors
  • The expanded definition of "rural area" and how the change impacts your institution; and
  • What tools are available from the Census Bureau and the CFPB to determine which areas are rural areas and how to use those tools.

Who Should Attend?

Auditors, compliance officers, loan officers, loan processors and other personnel with mortgage lending responsibilities