There are four types of Qualified Mortgages under the rule.
- General and Temporary QM definitions, can be originated by all creditors
- Small Creditor and Balloon-Payment QMs, can only be originated by small creditors
The QM requirements generally focus on prohibiting certain risky features and practices, such as negative amortization and interest-only periods and loan terms longer than 30 years.
QMs that are not higher-priced have a safe harbor, meaning that they are presumed to comply with the ATR
QMs that are higher-priced have a rebuttable presumption that they comply with the ATR requirements, but consumers can rebut that presumption.
If you need to ensure you have complied with the Qualified Mortgage and Ability-To-Repay Rules, you need Compliance EAGLE
-- the only compliance software that offers two QM solutions.