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ALERT: Policy Statement Requirement

Ability-to-Repay and Qualified Mortgages
 October 23, 2014









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It has come to our attention that state banking departments are now requesting a policy statement from licensees regarding the rules pertaining to the Ability-to-Repay and Qualified Mortgage.


I have lectured and written extensively about these subjects. For instance, relevant articles I have published include those found HERE, HERE, and HERE.  


Inevitably, state banking departments have determined that a policy statement is required to affirm that the licensee has an understanding of Ability-to-Repay (ATR) requirements and is cognizant of the factors pertaining to the Qualified Mortgage (QM) rule.


We have undertaken to provide such a policy statement, which combines a comprehensive overview of both ATR and QM. The policy is available to you at no cost, as a courtesy. The document is forty-four pages and offers a means to prepare for a regulatory examination. 


If you would like to download it, please click below. 


President and Managing Director   

LENDERS COMPLIANCE GROUP is the first full-service, mortgage risk management firm in the United States specializing exclusively in outsourced mortgage compliance and offering a full suite of services in residential mortgage banking for banks and non-banks. We are pioneers in outsourcing solutions for residential mortgage compliance. We offer our clients real-world, practical solutions to mortgage compliance issues, with an emphasis focused on operational assessment and improvement, benchmarking methodologies, Best Practices, regulatory compliance, and mortgage risk management.
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