Ability to Repay and Qualified Mortgage Audit Worksheet

Updated 10/25/2021

This tool provides a checklist for Regulation Z, § 1026.43, ATR and QM requirements and addresses amendments to these requirements under the Consumer Financial Protection Bureau. The key takeaways are:

  1. The General Qualified Mortgage (QM) definition now eliminates the 43 percent debt-to-income requirement and adopts price-based thresholds.
  2. Appendix Q is removed and no longer applicable under Regulation Z for the purposes of ability-to-repay determinations.
  3. Small Creditor asset threshold is $2.230 billion measured by the end of either of the two preceding calendar years for applications received before April of the current year, the Bank had total assets of less than $2.230 billion, to be adjusted annually, for inflation.

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