HUD proposes QM definition

HUD eliminate any interest rate threshold from the QM calculation, and establish a system where safe harbor treatment is provided to all loans that meet HUD’s proposed QM definition. Under this approach, there would not be two definitions for QM, which means that the APR- APOR spread would be discarded for purposes of FHA QM.

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HUD Proposes Rules to Define QM. In order to meet HUD’s QM definition, mortgage loans must: Require periodic payments; Have terms not to exceed 30 years; Limit upfront points and fees to no more than three percent with adjustments to facilitate smaller loans (except for Title I, Section 184 and Section 184A loans);

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HUD also proposed different standards for determining whether a loan is a rebuttable presumption QM or safe harbor QM. On September 27, HUD released a proposal defining what constitutes a "qualified mortgage" (QM) for purposes of loans insured by the FHA.

HUD’s proposed rule provided a detailed description of the policy and factors that HUD considered in developing a definition of "qualified mortgage" for the mortgages that it insures, guarantees, or otherwise administers.

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Unlike the CFPB, HUD’s definition is not designed for the general lending market but for the lenders who participate in HUD’s mortgage insurance and guarantee programs, and the borrowers who utilize mortgages under HUD’s programs, and, as previously noted, the Dodd-Frank statute is clear that HUD’s definition of "qualified mortgage" is

HUD is seeking the public’s comment on its proposed rule by Oct. 30th. The dodd-frank wall street reform and Consumer Protection Act requires HUD to propose a QM definition that is aligned with the.