A Message From IMA President Tim Lamb
Association Updates
IMA Seeks Nominees for Mortgage Pro of the Year
The Iowa Mortgage Association is pleased to announce the formation of the Mortgage Professional of the Year Awards. Two awards will be given at the 2021 IMA Fall Conference on Oct. 12 to recognize a distinguished mortgage professional from a financial institution and an outstanding associate/vendor partner.

Nominees symbolize excellence in the following categories:
  • Represents themselves, their company and the industry with the highest standards of ethics and excellence.
  • Demonstrates a continued commitment to community involvement.
  • Has made a significant contribution to the mortgage industry.
  • Is a member in good standing of the IMA.

Nominations must be submitted by Aug. 11.
Industry News
Revised QM Rule Delayed
On April 27, the Consumer Financial Protection Bureau formally delayed the mandatory compliance date of the General Qualified Mortgage final rule from July 1, 2021, to Oct. 1, 2022. The delay also extends the GSE QM expiration until Oct. 1, 2022. This final rule extends the General QM Final Rule’s mandatory compliance date, but it does not change the General QM Final Rule’s effective date of March 1, 2021. The CFPB also published an Executive Summary covering the final rule.

For applications received on or after March 1, 2021, but before the mandatory compliance date of Oct. 1, 2022, creditors that seek to originate General QM loans have the option of complying with either the revised, price-based General QM loan definition or the original, total monthly debt-to-total monthly income based General QM loan definition. Only the revised, price-based General QM loan definition is available for applications received on or after the Oct. 1, 2022 mandatory compliance date.

Delaying the final rule’s compliance date also gives lenders more time to use the government-sponsored enterprise patch, which provides QM status to loans that are eligible for sale to Fannie Mae or Freddie Mac. However importantly, the CFPB noted the availability of the GSE Patch after July 1, 2021 may be limited by recent revisions to the Preferred Stock Purchase Agreements entered into by the Department of the Treasury and the Federal Housing Finance Agency, which oversees the conservatorship of Fannie Mae and Freddie Mac.
Fannie and Freddie Signal End of GSE QM
Fannie Mae and Freddie Mac announced in early April recent amendments to their Preferred Stock Purchase Agreements with the U.S. Department of Treasury will imposes additional criteria on loans they purchase. The PSPA requires that loans Fannie and Freddie purchase with application dates on or after July 1, 2021 must meet the revised, price-based General Qualified Mortgage definition that became effective March 1, 2021. This move effectively signals the end of the GSE QM for applications dated on or after July 1, 2021. Although the CFPB has delayed the July 1 mandatory compliance date for the revised, price-based General QM final rule and expiration of the GSE QM, Fannie and Freddie have indicated they will purchase ONLY loans with application dates after July 1 that meet the revised General QM standards. Fannie and Freddie clarified, however, they will continue to buy loans that qualify as GSE QMs that have application dates on or before June 30 and are purchased as whole loans on or before Aug. 31 or in mortgage-backed securities pools with an issue date on or before Aug. 1.

Fannie and Freddie said they are continuing to assess the impact of the revised, priced-based General QM rule on their policies and operations and noted they do anticipate additional changes in eligibility and underwriting requirements that reflect aspects of the revised, price-based General QM rule. They also indicated additional details about the actual changes to policies and implementation, including impacts on Desktop Underwriter will be provided in future lender letters. IMA members that sell to secondary market vendors and/or directly to Fannie and Freddie are advised to consult with their investors regarding changes in policies and operations that will impact their mortgage production processes.
FFIEC Issues HMDA Updates
The Federal Financial Institutions Examination Council has issued the 2021 edition of its Home-Mortgage Disclosure Act guide, A Guide to HMDA Reporting: Getting It Right! for HMDA-related data collected in 2021 and reported in 2022. This compliance resource can help financial institutions better understand HMDA requirements, including the data collection and reporting provisions.
 
In related HMDA news, the Consumer Financial Protection Bureau has released HMDA modified loan application registers for approximately 4,400 financial institutions. The CFPB said it will publish additional HMDA-related information later this year, including a nationwide loan-level dataset that will provide all publicly available data from all HMDA reporters. Access the HMDA data.
Published by Iowa Mortgage Association