MPF Program Updates for Revised Qualified Mortgage Rule
Effective Date: July 1, 2021
In MPF Announcement 2021-41, the MPF Program provided some updates on implementation and compliance dates regarding the Revised Qualified Mortgage (“QM”) rule. This announcement provides further details related to implementation and compliance with the Revised QM rule for MPF Traditional.
Any policy detailed below that conflicts with MPF Guide provisions or prior MPF Announcements, is deemed to supersede such provisions or announcements. Until the policies described in this announcement are incorporated into the MPF Guides in a future publication, PFIs must abide by the policies provided for in this announcement.
Effective for MPF Traditional Conventional Mortgage Loans with Application Dates on or after July 1, 2021, the MPF Program will only accept mortgage loans that comply with the Revised QM Rule published on December 20, 2020. The requirements detailed in MPF Announcement 2021-41 will apply as follows:
- PFIs can begin applying these policies immediately but must apply them to all loans with application dates on or after July 1, 2021.
- Single-closing construction-to-permanent loans with application dates prior to July 1, 2021 that meet the current QM rule (and do not meet Revised QM rule) can be delivered on or before February 28, 2022.
- ATR Covered loans with application dates prior to July 1, 2021 may be delivered after August 31, 2021 provided the loans otherwise meet the Revised QM Rule and the MPF Program revised QM policies.
Assumptions may or may not be subject to the Revised QM Rule depending on the circumstances. PFIs must refer to the regulation for the applicable requirements.
Representations and warranties
PFIs will be responsible for representations and warranties related to the requirements as announced by the MPF program, for the life of the loan. The MPF Program, the MPF Provider and the applicable MPF Bank’s rights to exercise remedies related to violations of these requirements will not be waived.
The MPF Program, the MPF Provider and the MPF Bank will not make the determination of whether a loan complies with or is exempt from TILA, ATR, or the Revised QM Rule, or whether a PFI’s designation of a loan under the Revised QM Rule is correct. These determinations of compliance with the Revised QM Rule and other applicable laws are the PFI’s responsibility.
This announcement and any related future MPF Guide provisions supersede the terms of any waiver or exception granted to a PFI with terms that are inconsistent with the requirements of this announcement and any related future Guide updates.
Loan delivery and quality control
Certain delivery and quality control measures will be addressed in a future communication.
- MPF Announcement 2021-42