QM Math: Securing Your Safe Harbor
An Inside Mortgage Finance Webinar
Recorded August 1, 2013
The Consumer Financial Protection Bureau’s new qualified mortgage “safe harbor” promises to protect lenders if they can show that a loan met certain criteria at origination that presume the borrower has the ability to repay. But to reach that harbor, originators must navigate some complex calculations to determine if the points and fees fit under the 3 percent maximum and if the loan’s interest rate is below the threshold that would make it “higher-priced.” Routinely including the wrong numbers or misunderstanding how to apply them could put an entire portfolio of loans thought to be covered by the safe harbor into a riskier category and expose your organization to significantly increased liability.
Inside Mortgage Finance takes you step-by-step through what to include in your calculations and how to “do the math” during “QM Math: Securing Your Safe Harbor.” This very practical look at the complex math necessitated by the QM and Home Ownership and Equity Protection Act rules will help you clear this most-significant hurdle between noncompliance and compliance.
We look at the rule revisions that the CFPB issued in the summer and the “clarifications” they offered on underwriting issues. We also provide practical advice for how to figure points and fees, how to determine the correct average prime offer rate and how to make other calculations essential to classification as a qualified mortgage.
You’ll hear from:
- Richard J. Andreano, Mortgage Banking Group Practice Leader, Ballard Spahr
- Michael Chan, Vice President, ComplianceEase
- Donald C. Lampe, Partner, Morrison Foerster
- Ginger Moore, CRCM, AVP, Compliance Officer, PrimeLending
During the 90-minute recording, you’ll learn:
- How the rule revisions change the calculations,
- When compensation to a loan originator must be included in points and fees,
- What other items must be included in the points-and-fees figure,
- How to determine that a loan is not “higher-priced,”
- How GSE and government-insured loans must be treated, and
- How an automated system can secure your safe harbor.