Understanding QM: What the CFPB really means by ‘total loan amount’

The Consumer Financial Protection Bureau’s new ability-to-repay/qualified mortgage rule provides that a loan cannot be a QM if the points and fees paid by the consumer exceed certain thresholds based on the total loan amount. However, determining the total loan amount may be more difficult than it first appears. Read on to learn what a top compliance attorney had to say about the calculations involved in making this determination.