QM FOR MAC PATCH

To be eligible for purchase by Fannie Mae, QM Patch loans must: In particular, in Fannie Mae Lender Letter 2021-09, Fannie Mae indicated it will no longer acquire loans that are QM Patch loans that do not meet the revised QM rules. This вЂњoptionalityвЂќ has been partially negated by the GSEsвЂ™ April 2021 pronouncements in which they announced that they, in effect, will adhere to the mandatory effective date of the revised QM rules as originally promulgated by Kraninger in December 2020. Notably, under this rule, the QM Patch is extended to October 2022, which gives creditors the option of originating QM rules under either the legacy QM rules or the revised QM rules between Maand October 1, 2022. On April 27, 2021, the CFPB promulgated a final rule delaying the mandatory compliance date of the revised QM rule from Jto October 1, 2022. Under the rulemaking, the QM Patch would have expired on the earlier of Jor the date that the GSEs exit conservatorship. The rule was to take effect on March 1, 2021, but compliance would not be mandatory until July 1, 2021.

QM FOR MAC MAC

The revised QM rules also terminated the QM Patch, under which certain loans eligible for purchase by Fannie Mae and Freddie Mac do not have to be underwritten to Appendix Q or satisfy the capped 43% DTI requirement. On December 10, 2020, former CFPB director Kathy Kraninger issued the revised QM rules that replaced Appendix Q and strict 43% debt-to-income ratio (DTI) underwriting threshold with a priced-based QM loan definition. Under that CFPB rulemaking, during the period between Maand October 1, 2022, the CFPB intends for creditors to have the option of originating QM loans either under the legacy QM rules, including the QM Patch, or the revised QM rules. This development contradicts the Consumer Financial Protection BureauвЂ™s (CFPB) final rulemaking delaying the mandatory effective date of the revised QM rules until October 1, 2022. Stated another way, since the FHFA is terminating the QM Patch, loans underwritten to the QM Patch after Jwill no longer be eligible for sale to the government-sponsored enterprises (GSEs), and in effect, the QM Patch disappears after that date. Whether they realize it or not, absent a last-minute intervention from the Federal Housing Finance Agency (FHFA), effective July 1, 2021, creditors will no longer be able to originate qualified mortgage loans using the вЂњQM Patch.вЂќ The reason for this dramatic event is that on April 8, 2021, Fannie Mae and Freddie Mac announced in separate pronouncements that effective for loans with application dates after J(for Fannie Mae for Freddie Mac, applications received on or after July 1, 2021), the loans must conform with the revised qualified mortgage (QM) loan rules-and cannot be QM Patch loans.

Qm for mac