Does anyone plan to code their loans as QMs, ATR, Non-ATR, etc, at booking?

I can see why this would be beneficial from a risk & documentation standpoint.

I would think this would be very beneficial. I am goint to check with my Operations officer to see what our options are.

Check with your core processor. Some are adding fields so that they can be coded and produce reports.

We are going to track QM/ATR/Exempt Status and we are going to track the Rate Spread. That way we know if we have an Higher Priced Covered Transaction or not on the QMs.

I think this type of tracking will be very important going forward, for risk management, for future sales, in case of a law suit (!), etc.

Not that I disagree, but depending on what you plan on tracking and how well you plan to comply, it might also be a great big bullet in a class action lawsuit.

How else will you know not have a big pile of loans and not know what are subject to what rules....QMs that can be sold in 3 years, why you determined it was a QM, etc.? Do you want to have to go through each and every file to determine what you have?

I sure hope no one asks me to help them on that project.

From what I am being told, Jack Henry is working on this. So we may be ahead of the game, on at least this.