Ability-to-Repay & Qualified Mortgages Review & Update
Now a year since implementation, reports of problems are drifting in from examiners and auditors. This review will help you avoid violations and increase the likelihood of obtaining QM status.
Revisions to Regulation Z to implement the ability-to-repay (ATR) and qualified mortgage (QM) rules were effective January 10, 2014. Now a year later, reports of problems are drifting in from examiners and auditors. While most creditors seem to be getting clean reports, some are being cited for violating basic provisions of the rules. Others have errors that are not violations but result in a failure to obtain QM status for some loans. This webinar provides a thorough review of the ATR and QM rules.
No one wants the stigma of Truth-in-Lending violations. The loss of QM status is not a violation of § 1026.43 but can result in violations of other sections of the regulation and increases potential liability for the creditor. This program helps creditors avoid violations and increases the likelihood of obtaining QM status. It provides a thorough review of the ability-to-repay and qualified mortgage rules of Regulation Z. Participants receive a detailed manual that serves as a handbook long after the program is completed.
- Which transactions are covered by the ATR and QM rules in § 1026.43;
- Which transactions are exempt from the rules;
- The three options that allow balloon loans;
- What constitutes a higher-priced covered transaction;
- The basic repayment ability requirement;
- How to verify debt and income;
- The two non-QM ATR options:
- The 8 factors in § 1026.43(c)(2);
- Refinancing of Non-Standard Mortgages in § 1026.43(d);
- The five QM options:
- General Qualified Mortgages in § 1026.43(e)(2);
- Special Rule Qualified Mortgages in § 1026.43(e)(4);
- Small Credit Portfolio Loans in § 1026.43(e)(5);
- Temporary Balloon Payment QM in § 1026.43(e)(6); and
- Regular Balloon Payment QM in § 1026.43(f).
- Recordkeeping requirements.
Jack Holzknecht, CRCM, is CEO of Compliance Resource, LLC. He has been delivering the word on lending compliance for 38 years. Jack’s career began as a federal bank examiner. He also headed the form and software division of a regional consulting company. He has developed and presented training programs to bankers in 43 states. He also developed and delivered training for the FDIC.
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Member price: $265.00 | Non member price $530.00
Member price: $280.00 | Non member price $560.00
Online: Visit the CBA Webinar Catalog
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