Understanding QM’s safe harbor and rebuttable presumption

The Dodd-Frank Act provided that qualified mortgages are entitled to a presumption that the creditor making the loan satisfied the act’s ability-to-repay requirements. However, the act did not specify whether the presumption of compliance is conclusive or is rebuttable. The CFPB’s final rule employs both approaches. Jed Mayk, a partner at Hudson Cook LLP, discussed the QM safe harbor and rebuttable presumption during a recent October Research LLC webinar. Read on for the details.