As adopted, Appendix Q of the QM rule requires items to be considered and verified for the two prior years, and requires well-documented projections for the following three years.
Roughly 75 percent of bank loan officers cited put-back risk by Fannie Mae and Freddie Mac as an important factor limiting their current ability or willingness to approve home-purchase loans.
Loan officer compensation to individual originator employees is included in the calculation of the QMs 3 percent limit on points and fees but the industry believes this is double counting.