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Qualified Mortgage (QM) Checker

Determine if a loan meets Qualified Mortgage requirements under the CFPB's ATR/QM rule. Input loan features, points and fees, and income verification to check QM compliance.

ATR/QMDodd-Frank rule
3%points & fees cap
30 yrmax term

Check QM Compliance

Enter loan characteristics to determine QM status.

$

Safe harbor: ≤ 1.5% | Rebuttable presumption: 1.5%-2.25%

Negative Amortization
Interest-Only Payments
Balloon Payment
Full Income Documentation

W-2, tax returns, pay stubs verified

Enter loan details and click "Check QM Compliance" to see results.

Understanding Qualified Mortgage Rules

The Qualified Mortgage rule is part of the Ability-to-Repay (ATR) provisions under the Dodd-Frank Wall Street Reform and Consumer Protection Act. The CFPB established QM standards to protect consumers from risky mortgage features while providing legal protections for lenders who make responsible loans.

Safe Harbor QM

Safe harbor QM loans provide conclusive legal protection for lenders. A loan receives safe harbor status when its APR does not exceed the Average Prime Offer Rate (APOR) by more than 1.5 percentage points for first-lien loans (or 3.5 percentage points for subordinate liens). With safe harbor, borrowers generally cannot successfully claim the lender violated the ATR rule.

Rebuttable Presumption QM

Higher-priced QM loans (APR exceeds APOR + 1.5% but is within APOR + 2.25% for first liens) receive rebuttable presumption status. This means the loan is presumed to comply with the ATR rule, but a borrower can rebut this presumption by showing the lender did not make a reasonable determination of the borrower's ability to repay at the time of consummation.

Prohibited Features in QM Loans

These loan features automatically disqualify a mortgage from QM status, regardless of other factors.

Negative Amortization

Payment does not cover interest, principal balance grows

Interest-Only Payments

Payments only cover interest for a period

Balloon Payments

Large final payment exceeding regular payments (exceptions for small creditors)

Term > 30 Years

Loan maturity exceeds 360 months

Excess Points & Fees

Points/fees exceed 3% (for loans >= $110,260)

No Income Verification

Stated-income, no-doc, or NINA loans

Frequently Asked Questions

What is a Qualified Mortgage (QM)?
A Qualified Mortgage (QM) is a category of loan defined by the CFPB under the Ability-to-Repay (ATR) rule of the Dodd-Frank Act. QM loans must meet specific requirements including limits on risky features, points and fees caps, and income/debt verification standards. Lenders who make QM loans receive legal protection against ATR lawsuits.
What is the difference between safe harbor and rebuttable presumption QM?
Safe harbor QM provides conclusive legal protection — borrowers generally cannot claim the lender failed to determine ability to repay. Rebuttable presumption allows borrowers to challenge it. Under the 2021 revised rule, loans priced at or below APOR + 150 BPS receive safe harbor status.
What are the QM points and fees limits?
For QM loans of $100,000 or more, total points and fees cannot exceed 3% of the loan amount. Smaller loans have higher caps ranging from 5% to 8%. Points and fees include origination charges, discount points, and certain other fees.
What loan features disqualify a loan from QM status?
A loan cannot be a QM if it has negative amortization, interest-only payments, balloon payments (with limited exceptions), a term exceeding 30 years, or points and fees exceeding the applicable threshold.
How does the revised General QM rule (2021) work?
The revised rule replaced the 43% DTI cap with a price-based approach. QM status is now determined by comparing the loan's APR to the APOR. If the APR does not exceed APOR + 225 BPS for first-lien loans, the loan can qualify as a General QM regardless of DTI ratio.
What is the Ability-to-Repay (ATR) rule?
The ATR rule requires creditors to make a reasonable, good-faith determination that a consumer can repay a residential mortgage loan. Creditors must consider at least 8 factors including income, employment, monthly payments, debt obligations, DTI ratio, and credit history.

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