Monday, July 25, 2011

Proposed Alternative Definitions for Qualified Mortgage

Act Dodd - Frank a creditor to make a residential mortgage loan unless the creditor makes a reasonable and good faith, verified the consumer a reasonable determination that prohibits the ability to repay the loan.should be based and the fully indexed rate, the payment of any liens with the consumer, current liabilities, consumer DTI ratio, or residual income, and consumer credit history, applicable taxes, insurance and payment of assessments.

Frank Dodd's ability to pay for a requirement also provides for an estimate of compliance with "qualified mortgage."Major rule under the proposed alternative definitions of the two terms are about the issue "qualified mortgage." Comment period July 22, 2011 ends and the final rule will be implemented by the new Consumer Financial Protection Bureau.

Qualified mortgage creditors providing for the safe harbor definition

The first alternative definition, a covered transaction if a creditor has changed the rules a "Qualified Mortgage" (QM) will be commensurate with ability.

In addition, the QM can not exceed a loan term is 30 years.
Total points and fees payable in connection with a QM-based tiered may not exceed a limit. Proposed two alternative tiered threshold is based.
Tiered thresholds based on an alternative:

- Score more than 3% of the loan amount to $ 75,000
Total 3.5% - $ 60,000 or greater and less than the loan amount to $ 75,000
Total 4% - $ 40,000 or greater and less than the loan amount to $ 60,000
Total 4.5% - $ 20,000 or greater and less than the loan amount to $ 40,000
At least the credit amount of $ 20,000 - Total 5%
Tiered based Threshold Alternative 2:

- A loan for an amount equal to or greater than $ 75,000 total 3%

A loan amount equal to or greater than and less than $ 20,000 to $ 75,000, according to the following formula -

The total loan amount - $ 20,000 = Z $
Z = Y $ x.0036 basis points basis points
500 basis points - Y = X basis points basis points
The total loan amount and fees allowed by X points x.01 =% points

- At least the loan amount to $ 20,000: total 5%

period will repay the loan amount or outstanding principal balance as of the date the interest rate adjusts to the maximum rate. Creditor to account for any mortgage-related obligations in accordance with this provision of the loan to underwriting.


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