- emphasize that an institution may originate both QM and non-QM residential mortgage loans, based on the institution's business strategy and risk appetite;
- will not subject a residential mortgage loan to safety-and-soundness criticism based solely on the loan's status as a QM or a non-QM;
- continue to expect an institution to underwrite residential mortgage loans in a prudent fashion and address key risk areas in residential mortgage lending, including loan terms, borrower qualification standards, loan-to-value limits, documentation requirements, and portfolio and risk management practices;
- do not anticipate that a creditor's decision to offer only QM loans, absent other factors, would elevate a supervised institution's fair lending risk; and
- believe a decision to originate only QM loans is compatible with meeting Community Reinvestment Act obligations.
FDIC-Supervised Banks (Commercial and Savings) and FDIC-Supervised Savings Associations
Chief Executive Officer
Chief Compliance Officer
Chief Credit Officer
Ability-to-Pay and Qualified Mortgage Standards Rule at http://files.consumerfinance.gov/f/201309_cfpb_titlexiv_updates.pdf
Interagency Statement on the Ability-to-Pay and the Qualified Mortgage Rules (PDF Help)
Beverlea S. Gardner, Senior Examination Specialist, at firstname.lastname@example.org or 202-898-3640; or Paul Robin, Section Chief, at email@example.com or 202-898-6818
FDIC Financial Institution Letters (FILs) may be accessed from the FDIC's Web site at http://www.fdic.gov/news/news/financial/2013/index.html.
To receive FILs electronically, please visit http://www.fdic.gov/about/subscriptions/index.html.
Paper copies may be obtained via the FDIC's Public Information Center, 3501 Fairfax Drive, E 1002, Arlington, VA 22226 (877-275-3342 or 703-562-2200).