The CFPB adopted rules creating a new Seasoned Qualified Mortgage (SQM) category under the QM/ATR provisions set forth in the federal Truth-in-Lending Act. The SQM category applies to first-lien, fixed-rate covered transactions that meet certain performance requirements. A SQM must be held in portfolio by the originating creditor or first purchaser for a 36-month period, comply with general restrictions on product features and points and fees, and meet certain underwriting requirements. The adopted rules become effective 60 days after publication in the Federal Register (around March 10, 2021). The mandatory compliance date for the adopted rules is July 1, 2021.
Click to view the CFPB Rule Adoption – Seasoned QM: https://www.tenaco.com/wp-content/uploads/2020/12/CFPB-Rule-Adoption-Seasoned-QM.pdf
