Affiliate vs. "Affiliate": What's the difference between QM and RESPA?
Yes, the definition of "affiliate" is different for purposes of the ATR/QM Rule than it is under RESPA. Here's how. I know it's...
Why don't more community banks partner with mortgage brokers?
Most of our clients are community banks. Most of these community banks avoid partnerships with mortgage brokers. Lately, we've seen a...
Are we too afraid of HPMLs?
We see a lot of lenders with policies prohibiting the origination of Higher-Priced Mortgage Loans. Lately, we've been asking: Why? HPMLs...
Here's a Sample Framework for an Ability-to-Repay Worksheet
Still need something to put in the loan file to document ATR/QM Compliance? Here's one way to do this. One of the easiest ways to limit...
When, exactly, is an adverse action notice necessary?
Let's take a quick look at the important issue of when to issue an adverse action notice. We're here today to discuss the adverse action...