On April 27, 2021, the CFPB announced it was publishing a final rule that will delay the mandatory compliance date of the new General QM definition to October 1, 2022. The CFPB proposed this change with a Notice of Proposed Rulemaking on March 3rd and accepted comment until April 5th. See our prior article: CFPB Proposes Delay of Mandatory Compliance Date for General QM Rule.
The delay in the mandatory compliance date has the effect of allowing creditors to continue to use the existing DTI limit in the General QM definition, as well as the temporary GSE exception allowed under the current QM rules. However, as the prior final rule revising the General QM definition was effective March 1, 2021, creditors may also now choose to use the new price-based limit instead. After the mandatory compliance date creditors may only use the new price-based limit for determining if a loan meets the General QM definition.
The new final rule will be effective on June 30, 2021, or just one day before the mandatory compliance date provided by the prior final rule that revised the General QM definition to prevent it from taking effect on July 1, 2021. Instead on June 30, 2021, the mandatory compliance date will be revised to October 1, 2022.
Note, while the CFPB has extended the mandatory compliance date with this final rule, the GSEs both recently announced their intention to require compliance with the revised General QM definition for all applications July 1, 2021 and after. See our article: GSEs Announce Plans to Limit Purchases to Loans Meeting Revised General QM Rule.
