While they are effective, the VA’s Frequently-Asked-Questions on the qualified mortgage interim final rule provide helpful guidance on certain aspects of Interest Rate Reduction Refinance Loans (IRRRLs) origination as they relate to the VA QM rule, according to an analysis by the Washington, DC, law firm K&L Gates. The intricacies of IRRRL treatment under the interim final rule suggest the product may continue to be subject to ambiguities disproportionate to its limited role in the mortgage marketplace, wrote authors Kristie Kully and Eric Mitzenmacher, attorneys with the firm. VA’s interim final rule provides that all VA loans are QMs. The authors note that while most VA loans are safe harbor QMs under the rule, certain streamlined refinance loans (IRRRLs) are entitled only to a rebuttable presumption. Under the VA interim final rule, an IRRRL is deemed to have safe harbor QM status if the ...