To minimize the risk that their newly minted mortgage loans will fail to comply with the CFPB’s ability-to-pay rules, originators, correspondent lenders and purchasers have begun using independent advisors to perform various quality control functions. Among those functions are ATR/qualified mortgage review, mortgage risk assessment and a mortgage defense package, according to Ron D’Vari, CEO of NewOak, an independent financial services advisory firm in New York City. The ATR/QM review consists of a three-step process (aimed at compliance with ATR/QM requirements) run in conjunction with a credit review or stand-alone, D’Vari said in an online blog post recently. “The first step is diagnostics involving standard due diligence review aimed at identifying deficiencies leading to potential liability for non-compliance with ATR ...