SAFE MLO Ability to Repay, QM & LO Compensation question: qualified mortgage points-and-fees limit

SAFE MLOAbility to Repay, QM & LO Compensation

A $100,000 first-lien loan closes in 2026 with $3,600 in points and fees. Does it meet the 2026 qualified mortgage points-and-fees limit?

A Yes, because the limit for this loan size is 5%, or $5,000
B No, because points and fees exceed 3% of the loan
C Yes, because the limit for this loan size is a flat $4,139
D No, because the limit is 3% or $3,000, whichever is less

Show the answer and explanation

Answer: C. Yes, because the limit for this loan size is a flat $4,139

For loans of $82,775 up to $137,958, the 2026 QM points-and-fees limit is a flat $4,139 rather than a percentage (12 CFR 1026.43(e)(3)(i)(B); 2026 figure, effective Jan 1, 2026). $3,600 is under $4,139, so the loan meets the limit even though $3,600 is 3.6% of the loan amount. The 3% cap applies only at $137,958 and above. Source: 12 CFR 1026.43(e)(3)(i) and comment 43(e)(3)(ii)-1.xii; 2026 adjustment, 90 FR 57890 (Dec 15, 2025), effective Jan 1, 2026 (as at 11 Oct 2026).

Common mistake

Applying the 3% cap to a mid-size loan that has a flat-dollar limit.

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Original study material mapped to the public NMLS Content Outline; not a real test question.Not affiliated with or endorsed by NMLS, CSBS or SRR. Verify figures and rules against current guidance before relying on them.