Newsroom
NAFCU seeks CU input on CFPB QM proposals
NAFCU is currently seeking comment from member credit unions on the CFPB's notice of proposed rulemaking (NPRM) earlier this month regarding the definition of a general qualified mortgage (QM) under the Truth in Lending Act (TILA). The association provided section-by-section analysis of the proposed rule in a NAFCU Regulatory Alert sent yesterday, as well as a second Regulatory Alert to brief credit unions on the extension of the Government-Sponsored Enterprises Patch (GSE) QM Patch sunset date.
In the first Regulatory Alert, NAFCU highlighted that the NPRM seeks to amend the QM definition in Regulation Z to replace the debt to income (DTI) limit by removing the current 43 percent threshold and replacing it with a price-based threshold.
Under the proposal, NAFCU noted, a loan would meet the QM definition only if the annual percentage rate (APR) exceeds the average prime offer rate (APOR) for a comparable transaction by less than 2.0 bps. The proposal retains the distinction between a safe harbor and rebuttable presumption QM loan. Under the proposal, certain first-lien transactions would be deemed safe harbor QMs if the APOR is less than 1.5 bps, and rebuttable presumption QMs if the APOR is less than 2.0 bps.
While the proposal removes Appendix Q, lenders are still required to consider the borrower's income, assets, and DTI ratio. Additionally, the proposal provides a higher threshold for loans with smaller loan amounts and subordinate-lien transactions.
Comments on the proposed rule are due to NAFCU Sept. 7; Comments are due to the CFPB Sept. 8.
The second Regulatory Alert highlighted the extension of GSE QM Patch's sunset date until the amendments to the general QM loan definition take effect and how the extension would impact credit unions.
Comments on the extension of the sunset date are due to NAFCU Aug. 9; Comments to the CFPB are due Aug. 10.
Share This
Related Resources
Add to Calendar 2024-03-26 09:00:00 2024-03-26 09:00:00 Ensuring Safety and Soundness with AI Listen On: Key Takeaways: [03:48] The regulators are very focused on fairness in lending especially when it comes to using AI and outside models. The industry is moving very fast. [08:25] Articulating a business use case and how partnering with a Fintech can support it is the first step in having a successful conversation with your board. [10:30] Talk to your account executive at your Fintech and have them help you overcome objections. [15:01] Plan for oversight. It is not set and forget it. Your regulators are going to want to know how you are overseeing that from a 3rd party risk management standpoint. [15:47] Have a handle on your reserves and capacity for lending and start small and grow slowly. Web NAFCU digital@nafcu.org America/New_York public
Ensuring Safety and Soundness with AI
preferred partner
Upstart
Podcast
Help Ease Your Members' Loan Payment Concerns
Planning, Auto Loans, Research
preferred partner
TruStage
Blog Post
The Value of Risk Management in Cybersecurity
preferred partner
DefenseStorm
Video
Add to Calendar 2024-03-13 14:00:00 2024-03-13 14:00:00 Digital Assets in Credit Unions: What Are the AML Risks? The digital asset boom is upon us. Like it or not, you have to deal with it effectively with your members, credit unions are on the frontlines of crypto adoption. Even the NCUA has been providing more and more guidance on different aspects of digital assets. You need to be prepared. How? By understanding the core basics of digital assets (specifically cryptocurrencies) the risks that it poses to credit unions and how you can be better prepared to handle issues when they arise. In this webinar, Understanding the Digital Assets Boom, you’ll focus on the basics of digital assets, a background of cryptocurrencies and types, the regulations that are established and the proposals that are being considered and how to position yourself to understand all of these components and include them in your day-to-day roles. Key Takeaways Comprehend the basics of digital assets including cryptocurrencies Understand currently established regulations and what the future has in store, specifically in 2024 Identify and remediate issues that arise in your credit union Register Now $295 Members | $395 Nonmembers(Additional $50 for USB)One registration gives your entire team access to the live webinar and on-demand recording until March 13, 2025Go to the Online Training Center to access the webinar after purchase » Who Should Attend NCCOs NCRMs Compliance and risk titles Education Credits NCCOs will receive 1.0 CEUs for participating in this webinar NCRMs will recieve 1.0 CEUs for participating in this webinar Web NAFCU digital@nafcu.org America/New_York public
Digital Assets in Credit Unions: What Are the AML Risks?
Credits: NCCO, NCRM
Webinar
Get daily updates.
Subscribe to NAFCU today.