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Course description

What do crackers, nuts, air, checks, and bank procedures all have in common?

They go stale.

In banking, developing a process that is compliant and works well is like hitting the jackpot.  “If it ain’t broke don’t fix it” is a common mantra in banking, for good reason.  When something works, there is no desire to spend the time, resources, and energy to possibly improve it.  Why bother?

Over time, that process matures into a dead-set procedure that nobody really understands or questions.   That is when it becomes dangerous.   Not only could there be new compliance issues with the legacy process, but also inefficiencies and flat-out errors that slowly morphed over time.

Everything needs a checkup, and the Ability-to-Repay / Qualified Mortgage rule is no exception.   Why are you doing what you are doing?   Is it still appropriate, and what is the best approach for compliance in your bank?  The rules have changed – some of them significantly – and some verdicts have literally passed on the matter.

So let’s take a fresh look at the ATR / QM rule and gain new perspectives on it.

With the revised General QM rule that became mandatory on October 1, 2022., do you fully understand the difference between the “old / legacy” General QM and the “new / revised” General QM?  What about a “Seasoned QM” – how do you get one of those?!  While some things have certainly changed (ahem, 43% DTI cap, I’m looking at you), plenty of things remain the same – like the types of legal protection (well, mostly), loan feature limitations and restrictions, and some of the underwriting requirements.  Plus, the Small Creditor QM is still alive and well, along with the EGRRCPA QM, the Balloon QM, and the good old baseline ATR “non-QM”.   This session will help you keep it all straight!

This webinar is an absolute must if your bank:

  • Is under $10 Billion;
  • Holds any consumer mortgage loans in portfolio;
  • Is trying to figure out how to qualify customers in a rising-rate environment
  • Makes Higher Priced Mortgage Loans (HPMLs);
  • Makes manufactured-home loans (with or without land);
  • Wishes to claim the Small Creditor Escrow Exemption;
  • Makes balloon loans (or wants to);
  • Is a “Small Creditor”;
  • Is a “Rural / Underserved” lender;
  • No longer has a clue what the difference is between HPML / HCML / and HPCT


Along the way, you’ll get some great resources and cheat-sheets to help keep everything straight.  It is complicated!

All of this information will be presented from the perspective and real-life experience of a veteran compliance pro (25 years!) who, like you, is currently working in the thick of it, as the voice of compliance detangling the tough stuff.



Compliance staff, loan administration / production staff, loan policy makers, loan officers making in-house dwelling-secured loans, and audit staff.


Rebekah Leonard

Rebekah F Leonard, CRCM is the Director of Compliance for a $6 Billion community bank in Montana, as well as the owner of Elucidate, LLC, a compliance training company based in Miles City, Montana. Rebekah has been in the finance and banking industry since 1995, beginning in private-lending before settling into banking, where she’s covered nearly all of it – from customer service and teller work, to loan processing and review, to security & business continuity, to ultimately overseeing CRA, BSA and all aspects of compliance as a senior leader. She has successfully navigated numerous FDIC Compliance, CRA, and BSA Exams. Rebekah has a bachelor’s degree in Organizational Leadership from Chapman University (Magna cum Laude), attended the American Bankers Association National Compliance School in 2003, and has held her Certified Regulatory Compliance Manager designation since 2006. She actually likes compliance (really!) and enjoys sharing her passion of it with others.

Course curriculum

  • 1


    • Access Webinar

  • 2


    • Slides

    • EGRRCPA 101 Revisions to TILA

    • Section 35 HPML Info Sheet

    • Section 32 High Cost Mortgage

    • QM Varieties

    • Questions and Answers


4 star rating

Taking a Fresh Look at Qualified Mortgages and the Abilit...


Excellent; however, I did before the webinar and now after it have trouble finding the handouts. A better prelim email could have helped. Hope I am able to...

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Excellent; however, I did before the webinar and now after it have trouble finding the handouts. A better prelim email could have helped. Hope I am able to find them.

Read Less