The Qualified Mortgage Safe Harbor may have Washed Away

Just when lenders might have thought they were protected from ability to repay (ATR) loans because originating qualified mortgages (QMs) provided safe harbor, it turns out that under the Truth in Lending law a borrower can allege the lender engaged in unfair and deceptive acts (UDAP) that led to the loan being unaffordable. Thus, a […]