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Home » Store » Profitability » Here’s How to Exclude Affiliate Fees from QM’s 3 Percent Cap Under the CFPB’s Final ATR Rule

Here’s How to Exclude Affiliate Fees from QM’s 3 Percent Cap Under the CFPB’s Final ATR Rule

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The Consumer Financial Protection Bureau may formally address the treatment of affiliate fees in the points-and-fees calculation for qualified mortgages under the agency’s ability-to-repay rule, which takes effect in just a few weeks. Until such a decision is made, industry representatives have put together some guidance on how to exclude such fees from that 3 percent cap. “There has been significant industry confusion concerning the extent to which affiliate fees are included in the points-and-fees calculation, particularly when only a portion of a fee is retained by an affiliate,” the Mortgage Bankers Association said early this week. The trade group has put together a document outlining its understanding of the CFPB’s definitive guidance, based on discussions with bureau staff, on the treatment of affiliate fees in both the qualified mortgage and the Home Ownership and Equity Protection Act points-and-fees calculations. “Please keep in mind...
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