BROUGHT TO YOU BY THE LETTER “Q”:The Qualfied Mortgage and Qualfied Residential Mortgage Joseph...
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Transcript of BROUGHT TO YOU BY THE LETTER “Q”:The Qualfied Mortgage and Qualfied Residential Mortgage Joseph...
![Page 1: BROUGHT TO YOU BY THE LETTER “Q”:The Qualfied Mortgage and Qualfied Residential Mortgage Joseph Pigg, Vice President and Sr. Counsel aba.com |1-800-BANKERS.](https://reader036.fdocuments.us/reader036/viewer/2022062404/551aaf9a550346856e8b4db9/html5/thumbnails/1.jpg)
BROUGHT TO YOU BY THE LETTER “Q”:The Qualfied Mortgage and
Qualfied Residential Mortgage
Joseph Pigg, Vice President and Sr. Counsel
aba.com |1-800-BANKERS
![Page 2: BROUGHT TO YOU BY THE LETTER “Q”:The Qualfied Mortgage and Qualfied Residential Mortgage Joseph Pigg, Vice President and Sr. Counsel aba.com |1-800-BANKERS.](https://reader036.fdocuments.us/reader036/viewer/2022062404/551aaf9a550346856e8b4db9/html5/thumbnails/2.jpg)
aba.com |1-800-BANKERS
TWO STANDARDS: ONE GOAL
• QM AND QRM both intended to improve underwriting
• QM sets outer boundaries of what is an acceptable loan (red light/green light)
• QRM provides exemption from risk retention
![Page 3: BROUGHT TO YOU BY THE LETTER “Q”:The Qualfied Mortgage and Qualfied Residential Mortgage Joseph Pigg, Vice President and Sr. Counsel aba.com |1-800-BANKERS.](https://reader036.fdocuments.us/reader036/viewer/2022062404/551aaf9a550346856e8b4db9/html5/thumbnails/3.jpg)
aba.com |1-800-BANKERS
QRM IS A SUBSET OF QM – as proposed a much smaller subset
qrm
QRM
QM
![Page 4: BROUGHT TO YOU BY THE LETTER “Q”:The Qualfied Mortgage and Qualfied Residential Mortgage Joseph Pigg, Vice President and Sr. Counsel aba.com |1-800-BANKERS.](https://reader036.fdocuments.us/reader036/viewer/2022062404/551aaf9a550346856e8b4db9/html5/thumbnails/4.jpg)
aba.com |1-800-BANKERS
GSE’s are exempt from QRM (while in conservatorship
• GSE exemption necessary to avoid disruption of mortgage market
• Justified due to full backing of federal government
• Makes it much harder to ever resolve GSE status
![Page 5: BROUGHT TO YOU BY THE LETTER “Q”:The Qualfied Mortgage and Qualfied Residential Mortgage Joseph Pigg, Vice President and Sr. Counsel aba.com |1-800-BANKERS.](https://reader036.fdocuments.us/reader036/viewer/2022062404/551aaf9a550346856e8b4db9/html5/thumbnails/5.jpg)
aba.com |1-800-BANKERS
QM/QRM and GSE standards should be more closely aligned
• .
aRevised QRM (and GSE standard)
QM
![Page 6: BROUGHT TO YOU BY THE LETTER “Q”:The Qualfied Mortgage and Qualfied Residential Mortgage Joseph Pigg, Vice President and Sr. Counsel aba.com |1-800-BANKERS.](https://reader036.fdocuments.us/reader036/viewer/2022062404/551aaf9a550346856e8b4db9/html5/thumbnails/6.jpg)
aba.com |1-800-BANKERS
Aligning QM/QRM and GSE standards makes sense
• QM still sets boundaries of acceptable loans – must be safe, with traditional features and with a proven ability to be repaid
• QRM is a subset – safe, traditional, repayable and with additional borrower qualifications –i.e.down payment
• GSE standards should be same as QRM – loans safe enough to gain full backing of taxpayers should also be safe enough to be sold to investors without additional risk retention