Seasoned Qualified Mortgage (Seasoned QM)
A Seasoned Qualified Mortgage (Seasoned QM) is a specific category of Qualified Mortgage (QM) that receives a Safe Harbor (conclusive presumption of compliance with the Ability-to-Repay (ATR) Rule Rule) regardless of whether it was a Higher Priced Mortgage Loans at origination. This status is granted to certain first-lien, Fixed-Rate Mortgages that have demonstrated a strong payment history over an extended period while held in the originating lender's portfolio [12 CFR § 1026.43(e)(7)].
Criteria for Seasoned QMs
To qualify as a Seasoned QM, a loan must meet the following criteria:
- Loan Type: Must be a first-lien, fixed-rate mortgage.
- Seasoning Period: The loan must have been held in the originating lender's portfolio for at least 36 months (the "seasoning period").
- Performance Standards: During the seasoning period, the loan must meet specific performance standards, including:
- No more than two delinquencies of 30 days or more.
- No delinquencies of 60 days or more.
- Original QM Requirements: The loan must have complied with the product features, points and fees, and underwriting requirements of a general QM at the time of origination.
The creation of the Seasoned QM category by the Consumer Financial Protection Bureau (CFPB) aims to provide greater certainty and protection for lenders who originate and hold high-quality, performing loans in their portfolios.
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