“The 22nd Real Estate Lending Survey had the participation of 182 banks. The data was collected from March 4, 2015 to April 17, 2015, and in most cases reports calendar year or year – end results. In other cases, data reflect current activities and expectations at the time of data collection. Of the survey participants, 68 percent of respondents were commercial banks and 32 percent were savings institutions. About 77 percent of the participating institutions had assets of less than $1 billion. This survey is especially important as it reflects the impact of the Qualified Mortgage Rule (QM) on banks under the new Dodd-Frank regulations since its effective date of January 2014.
•About 90 percent of loans originated by banks were QM compliant compared to 84 percent lastyear, which isconsistent with the TILAregulations establishing the QM safe harbor effective January 2014
•Similarly, approximately half of those surveyed originated primarily QM loans with non-QM loans restricted totargeted markets or products while one-third restricted lending solely to QM loans
•Approximately 80 percent of respondents expect the new regulations will continue tocause ameasurable reductionin credit availability with 19 percent characterizing the impact as severe
•High debt-to-income levels werecited asthe most likely reason why a non-QM loan did not meet QM standards,followed by lack of documentation and the interest rate exceeded available spread over the average prime offer rate
•The percentage of single family mortgage loans made to first time home buyers increased from 13 percent in 2013 to 14 percent in 2014 – the highest percentage in the survey’s history
•Approximately 54 percent of respondents state that regulations have a moderate negative impact on business, while 33 percent characterize the impact as extremely negative.”