The Department of Housing and Urban Development (“HUD”) issued a final rule defining a “qualified mortgage” (“QM”) for HUD – insured, guaranteed, oradministered single family residential mortgages. This final rule, which applies to all case numbers assigned on or after January 10, 2014, creates two types of qualified mortgages — a safe harbor and a rebuttable presumption (note that the definitions are different from the safe harbor and rebuttable presumption definitions set forth in TILA)— with different protections for
consumers and different legal consequences for lenders.
