Qualified Mortgage – ATR/QM Policy and Procedures

Description

The Ability to Repay (ATR) and Qualified Mortgage (QM) rules require a mortgage company to make a reasonable, good-faith determination—before or at the time a mortgage loan is consummated—that the borrower has the ability to repay the loan.

An ATR analysis is required for all residential mortgage loans and involves evaluating factors such as the borrower’s income, assets, and employment status. This policy outlines the procedures necessary to ensure that borrowers meet the qualification criteria based on the specific terms and conditions of the mortgage loan program.

The policy and procedures also provides clear guidance for mortgage production staff on what is expected and required to remain in compliance with ATR/QM regulations.