Qualified Mortgages for Dummies

by. Henry Meier

True to its word, the CFPB released a guide to implementing the qualified mortgage regulations.  The guide is the first of several the Bureau plans to release to help lenders, particularly small lenders, comply with the myriad of mortgage regulations to be phased in over the next year.  If Siskel and Ebert reviewed regulations instead of the latest movies, they would give it a posthumous two thumbs up.  Here are some additional thoughts.

  • The guide is intended to assist lenders in implementing the qualified mortgage regulations.  It is not intended to be, nor is it a substitute for sitting down and struggling through the actual regulations.  In other words, it’s a great document for someone who needs to get a general overview of the regulations and it is a useful supplement for the person responsible for implementing the regulations.
  • The manual is filled with implementation suggestions, but I love the list of practical considerations at the very end of the guidance.  For instance, if you haven’t already done so, you should be identifying the products and staff that will play a role in implementing the new mortgage regulations as a whole.  As Pamela Stephens pointed out in testifying before Congress yesterday, many credit union staff persons wear several hats, so it is crucial to get everyone in the same room and start thinking about who is going to be responsible for implementing the new requirements.  The CFPB also points out that you should be reaching out to vendors and clarifying in your contracts and policies precisely what it is they can provide you and what it is that they are guaranteeing.  For instance, one thing I would ask your vendor is how quickly software can be adjusted to account for new calculations of points and fees.
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