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John Zasada, Compliance Consulting Director, Financial Institutions Group

On Feb. 23, 2021, the Consumer Financial Protection Bureau (CFPB) issued a Statement on Mandatory Compliance Date of General QM Final Rule and Possible Reconsideration of General QM Final Rule and Seasoned QM Final Rule addressing two final rules previously issued:

  1. Qualified Mortgage Definition under the Truth in Lending Act (Regulation Z): General QM Loan Definition
  2. Qualified Mortgage Definition under the Truth in Lending Act (Regulation Z): Seasoned QM Loan Definition

Both have an effective date of Mar. 1, 2021, with the General QM Final Rule having a mandatory compliance date of July 1, 2021.

The CFPB indicated it will be revisiting the Seasoned QM Final Rule and changes are possible. A proposed rule is expected to be released soon to delay the July 1, 2021 mandatory compliance date of the General QM Final Rule. The CFPB indicated it will consider at a later date whether to initiate rulemaking related to other aspects of the General QM Final Rule.

For more information on the rules, contact Doeren Mayhew’s regulatory compliance specialists.