CFPB Issues New Rules for QMs and Creates "Seasoned QM"
On December 29, 2020 the CFPB published in the Federal Register two new final rules. One rule modifying provisions related to a “Qualified Mortgage” (QM), and another rule created a new type of QM called a “Seasoned Qualified Mortgage.” The two combined rules are just under 550 pages long, so the two linked posts will provide a general explainer of the relevant provisions of the two rules. Though the rules do address additional areas such as the “GSE patch” related to loans eligible for GSE purchase or guarantee, we will not address this in this post, but if you have an interest in these changes, we suggest reviewing the final rule.
And for those interested in the changes, but prefer to learn in a different method, TMHA is teaming up with the attorneys Jeff Barringer and Devin Leary-Hanebrink with the McGlinchey law firm to provide a webinar to TMHA members. More details soon as to how to register and virtually attend. The webinar is still to be determined, but we are currently looking to a date in February.
Both of these new rules go into effect 60-days after publication in the Federal Register, which means they will be effective on March 1, 2021. There will be a grace period during the transition from March 1 until mandatory compliance begins July 1, 2021.