SFA QM VSH Scope of Review

The goal of the QM VSH Scope of Review is to create a uniform best practice testing standard to be utilized across TPR firms. The primary focus of this initial version of SFA’s TPR Scope of Review for QM VSH is to document the best practice approaches used by clients utilizing a TPR firm to perform due diligence on General QM loans under the new rule effective March 1, 2021.. As appropriate, SFA and its members will continue to work with the CFPB toward the goal of receiving formal regulatory guidance for the benefit of the consumer, primary, and secondary mortgage markets.  To that end, there may be shifts in the requirements should there be future CFPB rulemakings or formal guidance, or market developments.