![]() Both final rules become effective on March 1, 2021. The other final rule ( Seasoned QM Rule) 6 adds a new QM category (Seasoned QMs). One of the two final rules ( Amended General QM Rule) 5 modifies the requirements for a loan to qualify as a General QM as well as certain other provisions in the ATR/QM Rule and eliminates the GSE QM category (set to expire for applications received on or after the mandatory compliance date of the Amended General QM Rule). 3 Because of this, the ATR/QM Rule also gives lenders certain protections from such liability when making any one of several categories of "qualified mortgages" defined in the ATR/QM Rule, including a general category of QMs (General QMs) 4, the aforementioned GSE QM category and several other categories that are not affected by the final rules. However, evaluating consumers' ability to repay is complicated and can result in significant liability for lenders if they get it wrong. The ATR/QM Rule generally requires lenders, before making a residential mortgage loan to a consumer, to make a reasonable good faith determination of the consumer's ability to repay the loan according to its terms. ![]() 1 The principal purpose of these final rules is to avoid anticipated problems concerning mortgage credit availability following the scheduled expiration on Jof the so-called "GSE Patch," a temporary category of qualified mortgages (QMs) created as part of the original ATR/QM Rule for loans that are eligible for purchase by Fannie Mae or Freddie Mac (government-sponsored enterprises or GSEs), while operating under the conservatorship or receivership of the Federal Housing Finance Agency (GSE QMs). The Consumer Financial Protection Bureau (CFPB) recently published two final rules revising its Ability-to-Repay/Qualified Mortgage Rule (ATR/QM Rule).
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