The VA definition for a Safe Harbor Qualified Mortgage in general encompasses any loan guaranteed by the VA; however, the VA carved out additional requirements in the rule before an IRRRL will qualify as a Safe Harbor loan—if the loan doesn't meet the additional requirements then it will be considered a Rebuttable Presumption loan.
IDS Compliance completed a huge project to implement the new VA Qualified Mortgage test into its proprietary software system. The implementation includes several new audits available for IDS Customers to review on the QM page in the Settings section of the IDS website. Also, to help IDS customers comply with the new Safe Harbor requirements of a VA IRRRL QM, IDS has developed a checklist that logically walks creditors through the steps that ensure Safe Harbor status will be achieved on the IRRRL. Be sure to watch for the checklist in your VA IRRRL packages.
IDS Compliance wants to remind its customers that this VA interim final rule defining QM was published and effective on May 9, 2014, which also means that the CFPB's temporary definition of QM for VA loans has effectively come to an end. IDS implemented the changes at 5 pm on Tuesday, May 20, 2014. IDS made the changes effective for loans with an application date of May 9, 2014, or later.