Heres How to Exclude Affiliate Fees from QMs 3 Percent Cap
December 16, 2013
The Mortgage Bankers Association has put together some guidance, drawn from conversations with CFPB staff, on how to exclude affiliate fees in the points-and-fees calculation for qualified mortgages under the agencys ability-to-repay rule, which takes effect in just a few weeks. The bureaus ATR and Home Ownership and Equity Protection Act rules contain a cap or limit on points and fees to qualify as a QM loan and a specific points-and-fees threshold triggering HOEPA coverage. The calculation of points and fees under both of these...