QM Points and Fees Fee Calculation Regulation and Compliance

The final qualified mortgage or “ability to pay” rule  provides that fees earned by companies affiliated with a lender, including title insurance companies, must be included in the calculation of points and fees.  For banks affiliated with title insurers, this requirement could cause more mortgage loans made by those banks to fail to qualify as QM loans.

ABA's Position 

ABA supports the enactment of an amendment to the Dodd-Frank Act to fix the points and fees limitation in the QM Rule.


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