Understanding QM: LO comp and the concurrent proposal

The ultimate impact of the ability-to-repay/qualified mortgage rule is not clear, in part because the Consumer Financial Protection Bureau proposed a number of important rule revisions when it released the final rule. The proposal seeks comment on certain outstanding issues related to loan originator compensation under the ATR rule’s QM points and fees provisions. Read on to learn what a top compliance attorney had to say about the alternatives the bureau set forth for determining what loan originator compensation must be counted toward points and fees