Q&A: The Silent Risk Behind FNMA Points and Fees Rules

Answer:

Q: Is there a silent risk in assuming FNMA points‑and‑fees rules apply to non‑QM loans?
A: Yes, the silent risk is over‑restricting your pricing. FNMA’s points‑and‑fees limits only apply to Qualified Mortgage (QM) loans. Since non‑QM loans fall outside the QM framework, those caps do not apply.

Q: What actually matters for non‑QM?
A: Non‑QM loans still require full Ability‑to‑Repay (ATR) documentation, but they’re not bound by QM points‑and‑fees thresholds. Any limits you see are typically investor overlays, not regulatory requirements.

Q: What’s the takeaway for lenders?
A: Don’t let QM rules create a silent risk of missed opportunities. Non‑QM gives you more flexibility, as long as ATR is met and investor guidelines are followed.