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#QMPatch

The QM Patch Is Down for the Count

June 9, 2021 By Stephen Ornstein

Whether they realize it or not, absent a last-minute intervention from the Federal Housing Finance Agency (FHFA), effective July 1, 2021, creditors will no longer be able to originate qualified mortgage loans using the “QM Patch.” The reason for this dramatic event is that on April 8, 2021, Fannie Mae and Freddie Mac announced in separate […]

Filed Under: Ability to Repay/Qualified Mortgage, Consumer Financial Protection Bureau (CFPB), Federal Housing Finance Agency (FHFA) Tagged With: #QMPatch, QM

Fannie Mae and Freddie Mac Sunset the QM Patch

April 13, 2021 By Stephen Ornstein

The qualified mortgage (QM) rules have become a world of contradictions. In a client advisory, our Financial Services & Products Group investigates how the residential mortgage markets can thread the needle between new rulings from Fannie Mae and Freddie Mac and recent rulings from the Consumer Financial Protection Bureau.

Filed Under: Ability to Repay/Qualified Mortgage, Uncategorized Tagged With: #FannieMae, #FreddieMac, #QMPatch, QM

CFPB Retires the “QM Patch” and Revises QM Rules

December 28, 2020 By Stephen Ornstein

A&B ABstract: In a significant final rulemaking with potentially far-reaching consequences for the residential mortgage markets, the Consumer Financial Protection Bureau (“CFPB”) is terminating the “QM Patch” and significantly revising the criteria for what constitutes a qualified mortgage (“QM”) loan. Notably, in this rule, issued on December 10, 2020, the CFPB replaces the dreaded Appendix […]

Filed Under: Ability to Repay/Qualified Mortgage, Consumer Financial Protection Bureau (CFPB), Dodd-Frank Act, Mortgage Loans Tagged With: #AbilitytoRepay, #QMPatch, #QualifiedMortgage

CFPB Director Provides Update Relating to QM Patch Expiration

January 31, 2020 By Stephen Ornstein

  A&B ABstract: A recent letter from Consumer Financial Protection Bureau (“CFPB”) Director Kathleen Kraninger provides clues about the potential future of the so-called “QM Patch.” Discussion: In  a December 17, 2020 letter to Senator Mike Rounds (“Letter”), CFPB Director Kathleen Kraninger, revealed a number of interesting insights about the CFPB’s ongoing evaluation of the […]

Filed Under: Ability to Repay/Qualified Mortgage, Consumer Financial Protection Bureau (CFPB), Dodd-Frank Act, Mortgage Loans Tagged With: #QMPatch, ATR/QM

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