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A $320,000 first-lien loan closing in 2026 has an APR of 8.10%. APOR for a comparable transaction is 5.95%. Is the loan within the General QM price-based threshold?
For a first-lien loan of $137,958 or more (2026), a General QM's APR may not exceed APOR by 2.25 or more percentage points (12 CFR 1026.43(e)(2)(vi)(A)). Spread: 8.10 - 5.95 = 2.15, under 2.25, so the price test is met. At 1.5 or more the loan is a higher-priced covered transaction with only a rebuttable presumption of compliance, but it can still be a QM. The 3.5-point threshold is for smaller loans. Source: 12 CFR 1026.43(e)(2)(vi) and comment 43(e)(2)(vi)-3.v; 12 CFR 1026.43(b)(4); 2026 adjustment, 90 FR 57890 (Dec 15, 2025), effective Jan 1, 2026 (as at 11 Oct 2026).
Thinking a loan stops being a QM once the spread reaches 1.5 points.
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