Proposed Rule Summary: QM Definition Under TILA (Reg Z): Extension of Sunset Date, General QM Loan Definition, Seasoned QM Definition

Updated 09/14/2020

The Consumer Finance Protection Bureau proposed changes to facilitate a smooth and orderly transition away from the Temporary government-sponsored enterprises (GSEs) Qualified Mortgage (QM) loan definition and to ensure access to responsible, affordable mortgage credit upon its expiration.

  1. Extend the Temporary GSE QM loan definition in Regulation Z until the effective date of final amendments to the General QM loan definition in Reg Z (or when the GSEs cease to operate under the conservatorship of the Federal Housing Finance Agency (FHFA)).
  2. Remove the QM loan definition’s 43 percent debt-to-income (DTI) limit and replace it with a price-based threshold.
  3. Create a new category of QMs (Seasoned QMs) for first-lien, fixed-rate covered transactions that have met certain performance requirements over a 36-month seasoning period, are held in portfolio until the end of the seasoning period, comply with general restrictions on product features and points and fees, and meet certain underwriting requirements.

Members Can Download This Tool

Login to Download

Forgot password?


Not Yet a Member?

Our members enjoy:

On-demand regulatory guidance hotline – by chat, phone and email – available from anywhere, on any device – 7 am - 6 pm, M-F, Central time 

Research time saved daily/ weekly across forms, across checklists, across trainings — for every regulation

Hours of form-building and branding of bank documents saved; in some cases, even the budget of additional staff

A sounding board for support and reassessment when institutional goals or the regulatory environment changes

Access to attorneys and compliance specialists for risk modelling and decision-making in advance of large business decisions

The knowledge that C/A was created and owned by 29 State Bankers Association to provide bank compliance services to their membership organizations

Find out how a personalized team of attorneys and compliance professionals helps build targeted compliance strategies throughout your institution when you take our Live Membership Demo.

Become a Member