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Ability to Repay (ATR) & Qualified Mortgage (QM)

The ATR and QM requirements have been at the forefront of the mortgage-related rules issued by the CFPB. The rule became effective for most applications on or after January 10, 2014. Dodd-Frank amended the Truth in Lending Act to require that creditors must "make a reasonable and good faith determination based on verified and documented information that, at the time the loan is consummated, the consumer has a reasonable ability to repay the loan" according to its terms.

AMC believes that identifying gaps in compliance consistently and at an early stage is critical to its clients' efforts to understand and mitigate the risks associated with a particular transaction.

As such, AMC's ATR/QM Solution provides transparent insight into the details of each loan reviewed, including:

  • functionality to demonstrate underwriters have considered, verified and documented a consumer's employment, income, assets and obligations in order to determine the consumer's ability to repay
  • tools to re-test for key ATR and QM calculations, such as debt-to-income (including in accordance with Appendix Q), residual income and "points and fees"
  • the ability to determine whether "risky" loan terms or features are present
  • the ability to test a QM loan's APR for safe harbor status (under the CFPB final rule, as well other agency eligibility requirements)
  • the ability to test for Small Creditor QM requirements
  • the ability to test for "Non-standard" to "Standard" refinancing exemptions
  • Request Additional Information

Review types:

Ability to Repay & Qualified Mortgage
New requirements for 2014

Subject to ATR

Other CFPB Final Rules
Non-ATR/QM related requirements

Pre-Dodd-Frank Compliance
Legacy compliance testing for older loans

AMC clients include

Mortgage Originators Asset Backed Originators Banks Servicers Hedge Funds Insurers REITs RMBS Issuers Asset Backed Issuers Warehouse Lenders Law Firms
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