QM Status for Seasoned Loans
Despite its pending proposal to overhaul the entire definition of loans eligible for qualified-mortgage (QM) status, the CFPB proposes also to establish an additional class of first-lien, fixed-rate mortgages that are QMs or given a rebuttable presumption of QM status.
These loans must meet an array of restrictions, including those comparable to those otherwise governing QMs and those subject to rebuttable presumptions, except for a hard debt-to-income (DTI) ceiling and proposed pricing constraints.  Instead, these loans need only be held on a lender’s portfolio for three years and meet performance criteria during that time.