Danger Ahead: Avoiding Fair Lending Risk in the QM Era MP3 and Manual

Product Details

An Inside Mortgage Finance Webinar

Recorded March 5, 2014

The new qualified mortgage standard offers a promise of limited ability-to-repay liability if you adhere to its requirements. But, in an era where fair lending violations are discovered not through complaint but through statistical analysis, the very underwriting that verifies a QM loan could also be ammunition for a fair lending enforcement action. And while a bevy of federal regulators have said that “absent other factors” a QM-only strategy won’t set off fair lending alarms, their guidance didn’t offer any bankable promises, merely encouragements that mortgage lenders have been down this road before when the Home Ownership and Equity Protection Act rules went into effect.

Identify ways to steer clear of fair lending trouble while staying on course with the QM standards when you listen to this 90-minute program.

You’ll hear from:

• Paul Hancock, Partner, K&L Gates 

• Gregory Imm, Chief Compliance Officer & Director, Community Affairs/Fair Lending & Responsible Banking, Fifth Third Bank

• Maurice Jourdain-Earl, Managing Director, ComplianceTech 

• Andrew Sandler, Chairman and Executive Partner, BuckleySandler

During this recording, we cover such topics as:

• Does a QM-only policy expose you to too much fair lending risk? 

• What triggers a fair lending investigation?

• How can documentation procedures lessen the fair lending risk, especially if you make only QM loans? 

• What happens if you put tighter limits on credit than the QM maximums? 

• How can you assess the potential fair lending risk of a proposed QM-only strategy?

• What written policies and staff training should you have in place? 

• How can you design mortgage products that meet the QM standards without statistically excluding protected classes of borrowers?

• What lessons can be taken from HOEPA rule implementation?