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ARTICLE · 31 OCTOBER 2013

A Loan Policy For ATR And QM

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At the August Quarterly Meeting, we will present and discuss a very general outline of a Generic Loan Policy for the Ability to Repay and Qualified Mortgage Rules.

United StatesFinance and Banking
Edward Wilmesherr
Edward Wilmesherr
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At the August Quarterly Meeting, we will present and discuss a very general outline of a Generic Loan Policy for the Ability to Repay and Qualified Mortgage Rules. In order to facilitate that discussion and make that time as productive as possible, it seems advisable to provide a basic description of what that outline will entail. Here is where we begin to put on our thinking caps.

Between now and January 10, 2014, every bank that is subject to the Ability To Repay Rule will be faced with a basic decision: whether or not to originate Qualified Mortgages. We have already spent a lot of time and discussion considering what is required under the Ability to Repay Rule and what it will take for a loan to be a Qualified Mortgage. As we think about developing an outline of a Loan Policy for the ATR and QM Rules, we will only make passing reference to many of those requirements. Please refer to earlier Newsletter Articles and materials from our previous quarterly meetings for

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