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QM solutions: Affiliates and the Bank Holding Company Act
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Consumer Protection
Friday, April 18, 2014
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The ability-to-repay/qualified mortgage rule establishes a 3 percent points and fees cap for QMs and provides that any third-party charge retained by the creditor, loan originator or an affiliate of either must be included in points and fees. However, the rule relies on the definition of “affiliate” established under the Bank Holding Company Act, not the Real Estate Settlement Procedures Act definition many firms in affiliated relationships are familiar with. Paul Schieber, a shareholder at Stevens & Lee, says the BHC Act test that is used to determine whether a person or group has control over an entity is somewhat subjective. Read on to learn what he had to say about the issue during a recent October Research, LLC webinar.
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