Compliance is a top concern, of that there is no doubt. Most lenders are adopting strategies that will see them paying more attention to the new rules or bringing in extra help for quality assurance or even outsourcing compliance work to a third party. This issue doesn’t just impact bankers; it’s also a top concern for mortgage brokers.

The whole point of the Qualified Mortgage was to give the mortgage industry some product it could sell to consumers that carried with it a relatively high probability that it would not come back to haunt the originator in the future. Protection from buyback requests, a safe harbor from future losses, if you will, is what the whole thing is about. Given that, it’s in our best interest to explore the various safe harbors the regulator is building into the QM in order to assess its overall ability to reach that goal.