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pdfMortgage Lender Survey
This survey is being conducted by the Consumer Financial Protection Bureau (CFPB), a U.S.
government agency. The purpose of the study is to support the CFPB’s assessment of the ATR/QM
rule. This research will provide the CFPB with information regarding the effectiveness of the
ATR/QM rule in the marketplace. 1
Participation in this study is voluntary. In any public documents that result from this study, your
institution will not be identified and we will not disclose information in a manner allowing attribution
to specific institutions or individuals except to the extent required by law. More generally, the
Bureau’s confidentiality rules protect confidential commercial information provided to the Bureau.
Thus, the Bureau will not voluntarily disclose information in a manner attributable to your institution
unless it is required by law. If the responses you provide are requested under the Freedom of
Information Act, the Bureau will withhold such responses to the extent that it determines that they
constitute trade secrets or confidential commercial information that you would not ordinarily make
public. The Bureau will treat the responses consistent with its confidentiality rules, including 12
C.F.R. § 1070.20.
Anonymous participation is available to respondents. Although feedback provided by mortgage
lenders within the context of their identity is often most useful, we understand that some mortgage
lenders will prefer to remain anonymous and may choose not to participate otherwise. We appreciate
and encourage all feedback, including anonymous feedback, to enhance our ability to understand the
effectiveness of the ATR/QM rule in the marketplace.
This survey takes approximately 20 minutes. The full list of questions can be downloaded (as PDF)
from this LINK. You may want to review the questions ahead of filling out the survey, in order to
have the necessary information ready.
Thank you for your participation.
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For more information, see 82 FR 25246 available at https://www.federalregister.gov/documents/2017/06/01/201711218/request-for-information-regarding-ability-to-repayqualified-mortgage-rule-assessment
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Contact information
(Optional) Please provide the following details about your institution.
Institution name: _____________________________________________________________
Company NMLSR ID: ________________________________________________________
RSSDID (alternatively): _______________________________________________________
Contact information: __________________________________________________________
Permission to contact with follow-up questions: yes
no
Alternatively, if you wish to remain anonymous, please describe the type of your institution
as a mortgage lender.
General questions about your institution and mortgage lending activity
In this survey, the terms “mortgage” or “mortgage loan” refer to closed-end, 1-4 family
residential consumer mortgage loans. Do not include open-end loans, commercial or investor
loans, and chattel loans. All questions regarding the volume of lending activity involve counts of
loans, rather than dollar volume.
1. Which of the following options best describes the type of your institution? Choose one.
A bank with <$10 billion in total assets at the end of 2017
A bank with ≥$10 billion in total assets at the end of 2017
A credit union
A non-depository mortgage lender – an affiliate of a bank or a credit union
A non-depository mortgage lender – not an affiliate of a bank or a credit union
2. Which of the following options describe the ownership structure of your institution? Check
all that apply.
Our institution is a publicly traded company
Our institution is owned by its members
Our institution is owned by private individuals (other than members)
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Our institution is owned by a bank or a bank holding company
Our institution is owned by a non-bank financial / insurance company
3. Consider your 2013 business model. What specifically changed as a direct result of the
ATR/QM rule?
Does not apply (Our 2013 business model did not change as a result of the ATR/QM rule)
4. How many mortgages did your institution directly originate in 2017? Please use count of
loans.
0299
300499
500999
1,0001,999
2,0004,999
5,0009,999
10,00019,999
≥20,000
5. Among mortgages your institution originated in 2017, what was the combined share eligible
to be purchased, guaranteed or insured by a GSE, FHA, VA, or USDA/RHS?
Grid of values, 0 – 100%, endpoints included
6. Since 2013, did your share of mortgage loans eligible to be purchased, guaranteed or
insured by a GSE, FHA, VA, or USDA/RHS:
Increase by more than 5%
Decrease by more than 5%
Other
7. Did your institution provide services acting as a mortgage broker (i.e. helping originate the
mortgage but not providing the funding) in any of the following years? Check every year in
which you provided such services.
Provided services as a
mortgage broker
2013
2014
2015
2016
2017
8. What share of your 2017 mortgage originations was made through mortgage brokers (i.e.
mortgages where you provided the funding but relied on a mortgage broker to originate the
loan)?
Grid of values, 0 – 100%
9. How many mortgages for home purchase did your institution acquire through the
correspondent channel in 2017?
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0299
300499
500999
1,0001,999
2,0004,999
5,0009,999
10,00019,999
≥20,000
10. Please indicate the share of your 2017 mortgage originations that had the following
outcomes. Check all that apply.
>50%
1-50%
<1%
Sold to another financial institution shortly after origination
Sold directly to GSEs / Ginnie Mae / VA / USDA / RHS shortly
after origination (loans eligible to be purchased, guaranteed or
insured by a GSE, FHA, VA, or USDA/RHS)
Retained in portfolio (for at least 1 year after origination)
Non-QM originations and related policies
11. What share of your 2017 originations is represented by non-QM loans? Choose one option.
Did not originate non-QM loans
<1%
1-5%
>5%
Don’t know
12. If you have discontinued or materially modified mortgage product(s) for reasons related to
the requirements of the ATR/QM rule, please describe the product(s) in the text box below.
Be as specific as possible.
We have not made material changes to our mortgage products due to the ATR/QM rule
We have made the following changes described in the text box below:
13. Approximately, what percentage of your 2013 originations were generated by the
discontinued product(s)? Please include all products discontinued for reasons related to the
ATR/QM rule in your answer.
<1%
1-5%
5-10%
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>10%
14. Among the non-QM loans that you originate, do at least some of them have the following
features?
Yes
No
A jumbo loan with DTI>43%
A non-jumbo loan with DTI>43% (Only consider mortgages not eligible to be
purchased, guaranteed or insured by a GSE, FHA, VA, or USDA/RHS)
Borrower did not (could not) provide documentation required by Appendix Q (Only
consider mortgages not eligible to be purchased, guaranteed or insured by a GSE,
FHA, VA, or USDA/RHS)
15. In situations where DTI on a mortgage loan exceeds 43%, do you apply a pricing
adjustment in addition to regular LLPA’s? Only consider mortgages not eligible to be
purchased, guaranteed or insured by a GSE, FHA, VA, or USDA/RHS.
No such adjustment
Yes, we apply an adjustment
16. For each year, please indicate whether you qualified for a status of a Small Creditor under
the ATR/QM rule.
2014
2015
2016
2017
Eligible for Small Creditor
Eligible for Small Creditor
Operating in Rural/Underserved
Area
17. Please check every year in which at least 10% of your mortgage originations were coming
from rural areas.
Originated in rural areas
2013
2014
2015
2016
2017
18. Please check every year in which you have originated balloon loans.
Originated balloon loans
2013
2014
2015
2016
2017
19. Do you sell any of your non-QM loans to third parties? Choose one.
No, we keep all or almost all such loans on portfolio
Yes, we sell some of our non-QM loans
Yes, we sell most or all of our non-QM loans
20. Over the next year, do you expect your institution’s non-QM lending will:
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Increase
Stay about the same
Decrease
Questions regarding QM points and fees and related policies
21. Do you take the following actions when a loan application is being processed and there is an
indication that the QM cap for points and fees could be exceeded?
Yes
No
Waive certain fees to keep points and fees ratio under the limit, and increase
interest rate
Waive certain fees to keep points and fees ratio under the limit, without
increasing interest rate
Deny the loan application
Proceed without making any changes
22. How often does a loan application initially exceed the QM cap for points and fees? Please
only consider applications for loans of less than $150,000. Choose one option, and use the
text box below to provide additional detail.
Rarely or never (<1% of originations)
Sometimes (1-10% of originations)
Often (>10% of originations)
Don’t know
23. Do you include non-affiliated service provider fees into the QM points and fees calculation,
as an overlay? Check all that apply.
Yes, and the overlay is required by our institution
Yes, and the overlay is required by investors
No, we do not
Does not apply (such scenarios do not arise in our practice)
Questions regarding Appendix Q and related policies
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24. Describe any challenges you may have experienced in using Appendix Q for originating
mortgages not eligible to be purchased, guaranteed or insured by a GSE, FHA, VA, or
USDA/RHS. What types of borrowers are primarily affected? Please be as specific as
possible.
Does not apply (we do not originate such loans)
25. Did you make any adjustments to your institution’s requirements for documentation of
income for self-employed borrowers in 2013 or later in response to the ATR/QM rule?
Restrict your responses to mortgages not eligible to be purchased, guaranteed or insured by
a GSE, FHA, VA, or USDA/RHS. If yes, please provide additional details in the text box
below.
No, same requirements as before the rule
Yes, made changes
Does not apply (we do not originate such loans)
26. Do you apply Appendix Q requirements to GSE-eligible loans, as an overlay? Check all that
apply.
Yes, and the overlay is required by our institution
Yes, and the overlay is required by investors
No, we do not
27. Do you generally allow a borrower to use assets to supplement monthly income in order to
qualify for a loan? Restrict your responses to mortgages not eligible to be purchased,
guaranteed or insured by a GSE, FHA, VA, or USDA/RHS. Choose one.
No, we do not allow the use of assets
Yes (please briefly explain your approach in the text box below)
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28. How often do you qualify borrowers based upon a residual income approach? Restrict your
responses to mortgages not eligible to be purchased, guaranteed or insured by a GSE, FHA,
VA, or USDA/RHS. Choose one.
Rarely or never (<1% of originations)
Sometimes (1-50% of originations)
Often (>50% of originations)
Additional questions (only for structured interviews)
1. Please describe your mortgage business operations in 2013.
2. Has your institution’s post-ATR/QM mortgage operations changed as a result of the rule?
If so, how?
3. As a result of the ATR/QM rule, have you changed your approach to meeting community
reinvestment act obligations? If so, what specific changes have you made?
4. Compared to your 2013 mortgage operations, have you introduced any new products for
reasons related to the requirements of the ATR/QM rule?
5. Operationally, what are the key steps that you take to determine that a loan is QM?
6. Among your GSE eligible loans, what percentage of them do you end up selling to GSE’s,
and what percentage do you keep on the portfolio? Would you say you’ve been doing this
more or less after the rule?
7. Do you originate any non-QM loans? If so, what are the typical reasons for a loan to be nonQM in your practice?
8. Do you obtain non-QM loans or application for such loans from a broker or a
correspondent lender?
9. Going back to January 2014, are there loan level pricing adjustments that would apply to
non-QM loans? For example, do you charge extra for DTI>43% on loans that do not go to
GSE’s?
10. How would you compare the cost of originating a non-QM loan to the cost of QM loan?
11. Do you currently originate interest only loans?
12. What are the main barriers to growth of your non-QM segment?
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13. Do you operate in rural areas?
14. Do you use a residual income approach for loans other than VA loans? For what type of
borrowers?
15. How do you treat cases where a borrower has significant assets that could be put as
collateral? Or as a source of income?
16. When and how do you run the points and fees test?
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| File Type | application/pdf |
| Author | Kulaev, Sergey (CFPB) |
| File Modified | 2018-05-11 |
| File Created | 2018-05-11 |