Ability-to-Repay/Qualified Mortgage Review and Update
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?
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.
- 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.
Auditors, compliance officers, loan officers, loan processors and other personnel with mortgage lending responsibilities
Jack Holzknecht is the CEO of Compliance Resource, LLC. He has been delivering the word on lending compliance for 39 years. In 34 years as a trainer over 125,000 bankers (and many examiners) have participated in Jack’s live seminars and webinars. Jack’s career began in 1976 as a federal bank examiner. He later headed the product and education divisions of a regional consulting company. There he developed loan and deposit form systems and software. He also developed and presented training programs to bankers in 43 states. Jack has been an instructor at compliance schools presented by a number of state bankers associations. As a contractor he developed and delivered compliance training for the FDIC for ten years. He is a Certified Regulatory Compliance Manager and a member of the National Speakers Association.
Kelly M. Owsley, CRCM is Director of Training Services for Compliance Resource, LLC. Kelly’s career in banking began in 2000. Since then she has worked for financial institutions ranging in asset size from $250 million to $3 billion. Kelly has worked in numerous areas of the financial services industry including retail branch management, lending, product development and training. In addition, Kelly spent three years in a training and development role with CUNA Mutual Group servicing the largest credit union in the United States. Most recently, she served as the Vice President of Compliance, BSA Officer, and CRA Officer for a community bank in Kentucky where she was responsible for implementing and training all compliance related topics. Kelly holds a Bachelor of Science degree in Accounting from the University of Kentucky and is a Certified Regulatory Compliance Manager.
Institute of Certified Bankers: Visit http://www.icbmembers.org/login.aspx for instructions regarding self-reporting. Estimated credits: 2.5 CE Credits
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