New Points and Fees Test for Qualified Mortgage and High-Cost Mortgages

Financial Institutions

March 01, 2014
by John Moniak, CRCM

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John Moniak John Moniak, CRCM
Senior Manager - Regulatory Compliance

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Many of you have questions about what fees are included in the points and fees calculation for qualified mortgages and high-cost mortgages as well as how to determine the loan amount. It may seem simple at first; you have the numerator of the calculation being the points and fees, and you have the denominator being the total loan amount. But I am reminded of a statement in a television advertisement “no, no, no, not today.” The purpose of this article is to provide basic guidance; it is not intended to discuss all situations. You should review your particular case against the regulation to validate what to include in the fees for the points and fees and how to determine the total loan amount.

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Length: 3 pages (PDF 105 kB)



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