Comments Due to NAFCU: CFPB - Seasoned Qualified Mortgage Definition
NAFCU would like to highlight the following:
- A Seasoned QM will receive safe harbor QM status if the loan includes restrictions on product features and points and fees and meets certain underwriting and performance requirements after a 36-month seasoning period.
- During the seasoning period, a loan cannot have two delinquencies of 30 days or more, and no delinquencies of 60 or more days. A Seasoned QM must be held in portfolio for 36 months.
Comments due to NAFCU: September 25, 2020
Comments due to CFPB: September 28, 2020
NAFCU will send comments on behalf of its members to the NCUA by their deadline (September 25, 2020).