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Event Date Fri Apr 2 EDT (over 1 year ago)
Location TBA
Region All

NAFCU would like to highlight the following:
• The proposal would change the mandatory compliance date for the new General QM definition from July 1, 2021 to October 1, 2022.
• For applications received on or after March 1, 2021 and before October 1, 2022, credit unions would have the option to comply with the new Average Prime Offer Rate (APOR)-based General QM definition or the previous debt-to-income (DTI)-based definition that was in effect prior to March 1, 2021.
• Credit unions could utilize the Temporary Government Sponsored Enterprise (GSE) QM loan category (Temporary GSE QM or “GSE Patch”) until the proposed October 1, 2022 mandatory compliance date, or the date of the GSEs existing conservatorship, if earlier.
• The proposal makes no substantive changes to the General QM definition and the Bureau may reconsider the rule at a later date. The Bureau is proposing this delay to ensure access to responsible, affordable mortgage credit and preserve flexibility to consumers as the COVID-19 pandemic continues.