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The New Ability-to-Repay and QM Rule: An In-Depth Look at the Issues

Webinar: ID# 1000974
Date: Recorded
About This Course:
Of the many new rules the CFPB finalized this past January, among the most complex is the ability-to-repay and Qualified Mortgage (QM) rule. This rule alone will have dramatic implications for the mortgage marketplace and will impact the product-level decisions for every consumer mortgage lender in the country. How will your institution react? There are many decisions to be made.

In this webinar we'll discuss the precise requirements of the lender's duty to evaluate the consumer's ability to repay, including how to evaluate precisely what factors in the process. As well, we'll talk about the various types of Qualified Mortgages, or QMs, and what those definitions mean. There are differing legal standards for the different types, and understanding the implications involved is a critical strategic step your institution must take.

We'll also discuss what could happen if there are problems - it's not just the examiners you have to worry about here. There are significant legal risks that could halt the foreclosure process in its tracks, which could put a financial strain on your institution if things don't go smoothly.

We'll go in-depth on the details of the rule, its application, and the specific requirement to provide you a thorough understanding of what is required, along with the consequences.

Covered Topics:

  • Application of the rules - to what types of loan specifically?
  • The many exemptions, including partial exemptions
  • Refinancing a "nonstandard mortgage" into a "standard mortgage" - 6 required standards
  • What ability-to-repay is NOT
  • What are the 8 minimum underwriting factors in detail, and how are they detailed in the new Appendix Q?
  • Restrictions on prepayment penalties - what loans and what penalties
  • Qualified mortgages - different types and different standards
  • "Points and fees": what's included and what isn't
  • Balloon loans - can they be QMs?
  • Record retention requirements

Who Should Attend

Anyone involved in consumer mortgage loan (as well as other real estate-secured loan) operations, underwriting, servicing, and compliance will benefit from this session, including compliance officers, underwriters, senior management, bank counsel, and operations, among others.

Carl is an excellent speaker. If you have additional questions, he always follows up! - Brenda P., Northampton Cooperative Bank

The Presenter

Carl Pry is a Certified Regulatory Compliance Manager (CRCM) and Certified Risk Professional (CRP) who is a Senior Director for Treliant Risk Advisors in Washington, DC. Through his working career, as well as through his experience as a banking attorney and officer, he has provided a variety of regulatory compliance and financial performance services to financial institutions and other clients throughout the country. He has written extensively regarding consumer and commercial compliance, tax, audit, and financial institution legal issues, and is a frequent contributor to and currently serves on the Editorial Advisory Board for the ABA Bank Compliance magazine. He has spoken at dozens of banking, compliance, and state bar associations, and has conducted training sessions for financial institutions across the country.

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The New Ability-to-Repay and QM Rule: An In-Depth Look at the Issues
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