Credit unions can access a compliance guide and other resources provided by the CFPB. Hood said that credit unions should read the provisions of the General QM and Seasoned QM final rules to determine their effects on operations. In addition, Regulation Z contains several categories of QMs, including the General QM category. Loans that meet Regulation Z requirements for qualified mortgages obtain certain protections from liability. This ensures that Fannie Mae and Freddie Mac will get one more year of high mortgage profits despite the GSEs already have an unfair advantage due to the QM patch. The letter stated that, with some exceptions, Regulation Z requires lenders to make reasonable, good-faith determinations of a consumers’ ability to repay any residential mortgage loans. While the QM rule was set to expire in January 2021, it’s expiration has been delayed until October 2022.
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