The Consumer Financial Protection Bureau (CFPB) has proposed to delay the
mandatory compliance date of the General Qualified Mortgage
(QM) final rule
from July 1, 2021 to October 1, 2022. The rule, proposed last June, is designed
as a replacement for the so-called GSE patch. CFPB says it is proposing the extension
to ensure that homeowners struggling with the financial impacts of the COVID-19
pandemic have the options they need. 
As originally written at
the time of the housing crisis, the Ability to Repay/Qualified Mortgage Rule
(ATR-QM Rule) provided a safe harbor to protect lenders from lawsuits charging them
with failing to appropriately quantify a borrower’s ability to repayment a loan.
In general, the QM rule requires that a loan comply with prohibitions on
certain loan features, points, and fee limitations. It also requires that a
borrower’s a debt-to-income (DTI) ratio does not exceed 43 percent and that
creditors “calculate, consider, and verify debt and income for purposes of
determining the consumer’s DTI ratio using the standards contained in Appendix
Q of Regulation Z.” 


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