The QM Trace page allows loan officers and secondary users to view a breakdown of where a loan passes or fails QM calculations. Loan officers can review the QM trace from the search results before submitting a lock request. They can also review the QM trace any time after the loan is locked and before or after a change has been made. Secondary users can review the QM trace before accepting a lock request and after changes have been made, to ensure the loan still passes the QM test.
With the QM Trace, you can:
Identify the reasons why a loan falls out of QM limits
Analyze points, fees, and adjustments
Understand bona fide discount points and how bona fide discount points affect QM calculations
For a locked loan, you can use the QM Trace to view QM compliance based on current loan values, loan values at the time of lock request, and loan values at the time of lock acceptance. This allows you to analyze the effects of the loan value and product/pricing updates with respect to your QM policy.
NOTE: After creating custom QM policies, review the QM Trace on loans to verify that you are receiving the expected results.
- To view QM Trace results for a loan, do one of the following:
In the search results, click the QM Trace icon.
In the loan’s status bar, click the QM Trace icon.
- At the top of the QM Trace page, choose the radio button that allows you to display the values that you want to review:
View QM Trace with Current Loan Values—This option displays the values based on the current loan variables. This is the only option available for unlocked loans.
View QM Trace From Lock Request Loan Values—This option displays the values at the time of the lock request
View QM Trace with Lock Accept Loan Values—This trace reflects how this loan compares with the lender’s QM Policy. It is therefore a reflection of the lender’s interpretation of the CFPB and is not intended to reflect an official determination or to represent the analysis of any other organization.
The Current Loan Values table displays information about the loan, including loan amount, rate, and price.
- The QM Trace Information table displays how the current loan’s values compare to the lender limits (the currently applied QM Policy), CFPB limits (the Optimal Blue Global Default Policy), and whether the line item passes.
The Passes Lender Limit column displays a check mark or an X icon, indicating whether the loan passes the current lender’s QM Policy. The HPML icon indicates that the selection falls into rebuttal presumption as a HPML.
- The QM Points and Fees table displays a breakdown of the points and fees.
NOTE: This trace reflects how a specific loan compares with the lender’s QM Policy. It is therefore a reflection of the lender’s interpretation of the CFPB and is not intended to reflect an official determination or to represent the analysis of any other organization.