Helpful Resources for the Approaching ATR/QM Rule Effective Date

CFPB Qualified Mortgage

As the January 10, 2014 effective date for the ATR/QM Rule approaches, a number of questions remain about the requirements for QM and non-QM loans. Some of our clients have found the CFPB Comparison Chart outlining the contours of the rule helpful in gaining a general understanding of these requirements. In addition, we are assisting our clients with more difficult questions, such as how to comply with the underwriting requirements for non-QM loans and how to treat bona fide discount points, charges retained by affiliates, and fees paid for outsourced origination services under the QM points and fees test.

Please contact us if we can be of assistance on these or other matters. Questions may be directed to one of the lawyers listed below or to any other BuckleySandler attorney with whom you have consulted in the past:

• Jeffrey P. Naimon, Partner, (202) 349-8030, jnaimon@buckleyfirm.com
• Clinton R. Rockwell, Partner, (310) 424-3901, crockwell@buckleyfirm.com
• John P. Kromer, Partner, (202) 349-8040, jkromer@buckleyfirm.com
• Joseph M. Kolar, Partner, (202) 349-8020, jkolar@buckleyfirm.com
• Jon D. Langlois, Counsel, (202) 349-8045, jlanglois@buckleyfirm.com

For more information, insights, and observations on these issues from our attorneys, download our Special Alert on the final rule and Special Alert on amendments to the final rule, and visit BuckleySandler’s CFPB Resource Center.