HUD QM Rule Survey

Thank you for participating in this survey! Your responses to the following questions will enable the Association to draft a comprehensive, effective comment on this proposal.


1)

The CFPB defines a Qualified Mortgage (QM) as a mortgage that, among other things: 
 does not exceed 30 years;
 for a loan of $100,000 or more, limits points and fees to 3 percent of the total loan amount; and
 has a debt-to-income ratio no higher than 43 percent.

Under the CFPB’s rule, a QM that has an interest rate that does not exceed the Average Prime Offer Rate (APOR) for mortgages of similar lengths is given complete protection against legal actions and defenses. A QM mortgage that has an interest rate that does exceed the comparable APOR for similar mortgage loans by 1.5% is considered a higher priced mortgage and is given a presumption that it was properly underwritten. This means that a homeowner must prove, for example, that the loan was made without regard to his or her ability to repay the loan if he or she defaults on the loan.

A mortgage guaranteed or insured by HUD could qualify as a QM mortgage even if it exceeds a 43% debt-to-income (D-T-I) ratio. Which of the following statements do you agree with? (Please choose one.)








2)

HUD is maintaining the points and fee cap but is inviting comment on whether this cap is appropriate for HUD mortgages. Should HUD use a larger threshold for points and fees than has been promulgated by the CFBP?




3)


4)

When a member qualifies for an FHA loan, HUD (through the FHA) insures the lender against default. HUD is proposing that the cost of a member’s premium contribution not be counted when determining if a mortgage is either a QM loan or a higher priced QM loan. Which of the following statements do you agree with? (Please choose one.)







5)

Should HUD expand its definition of QM Mortgages?








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