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2020 left us with the gift of some new qualified mortgage final rules. Hi, there. This is Jared Moyer with Banker’s Compliance Consulting. With respect to these final rules, what’s something new that these rules bring to the table that wasn’t there before? Well, let’s start off with the fact that there’s a brand new qualified mortgage category called a seasoned QM, essentially a loan that’s made that’s not a QM at consummation, but you checked enough boxes that if it meets certain criteria, after a certain timeframe has passed, it will then be deemed a QM. Okay, there’s a whole lot going on with that one. And then collectively, that seasoned QM and then the new updated version of the general QM, are going to carry with it this new requirement that the lender document their use of and consideration of the minimum underwriting factors associated with that qualified mortgage category. Now that’s only going to apply to the seasoned and general QM, but that’s something new that wasn’t there before.
There’s a lot of other things that are new too. Like I said, that whole season QM category is new. And then probably your overall use of the general QM, you probably avoided that before because you used the temporary version. Well, that’s going to die off and you’re now going to be charged with having to probably get into some general QM loans, especially if you deal with investors and those in secondary market loans. There’s a lot of different resources we’re going to be trying to put together to help you with that implementation and change management. Training is just one of them. If you’re familiar with our website, we’ve got a laundry list of training options out there that will include qualified mortgage rule information. We’re also working on some tools and resources to put in our free downloads area.
If you’re looking for consultation and trying to get direction on this, we’d love to help you with that too. We’d love to be your trusted partner when it comes to implementing these new QM rules. Reach out to us today, give us a call, email us, we’ll talk to you about it, and figure out what the best direction is for you and get you moving in that direction.