How long must a creditor retain a loan to maintain QM status for Small Creditor QM and Balloon QM?

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For a creditor to maintain Qualified Mortgage (QM) status under the Small Creditor QM and Balloon QM provisions, they are required to retain the loan for a minimum duration of three years. This retention period is crucial because it ensures that the creditor can demonstrate compliance with the QM guidelines, which include limitations on debt-to-income ratios and other underwriting standards designed to protect borrowers from excessive financial burden.

Retaining the loan for this specified period not only reflects the creditor’s commitment to responsible lending practices but also helps in the management of risk associated with these types of loans. If a creditor sells a loan before the three-year retention period, it risks losing the protections afforded by QM status, which could lead to complications regarding borrower rights and potential liability issues.

Considering the context of the question, it is important to also recognize that shorter retention periods indicated in other choices do not fulfill the regulatory requirements established for maintaining QM status, which makes the three-year retention period the correct and necessary duration for compliance.

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