Federal Mortgage Law · 24% of the SAFE exammedium
Correct answer: May qualify as a QM if the APR does not exceed APOR by 2.25%
The CFPB's revised General QM rule (effective March 2021) replaced the prior 43% DTI cap with an APR-to-APOR comparison. A loan qualifies as a General QM if its Annual Percentage Rate (APR) does not exceed the Average Prime Offer Rate (APOR) by 2.25 percentage points or more for most first-lien loans — regardless of the borrower's DTI ratio. So a 50% DTI loan can absolutely be a General QM if the APR/APOR spread is within the threshold. Lenders must still consider and verify DTI, but there is no fixed DTI ceiling. "Cannot qualify as a QM because DTI exceeds 43%" reflects the outdated pre-2021 rule. "Automatically receives safe harbor protection" is wrong because safe harbor depends on pricing, not DTI. "Requires a manual exception from the CFPB" is fabricated — the CFPB does not issue manual QM exceptions.
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