HUDs QM Departs From CFPB On Division Between Legal Protection
October 7, 2013
Last week, the Department of Housing and Urban Development came out with its own version of a qualified mortgage rule for FHA-backed mortgages based largely on the QM standard incorporated in the CFPBs ability-to-repay rule early this year. Following the CFPBs QM definition, HUDs proposed rule defines both a safe-harbor QM and a rebuttable-presumption QM. HUDs QM definition also incorporates the points-and-fees limitation scale from the CFPBs final rule. The significant departure from the CFPBs definition is the way in...