As the January 10, 2014 effective date for the ATR/QM Rule approaches, a number of questions remain about the requirements for QM and non-QM loans. Some of our clients have found the CFPB Comparison Chart outlining the contours of the rule helpful in gaining a general understanding of these requirements. In addition, we are assisting our clients with more difficult questions, such as how to comply with the underwriting requirements for non-QM loans and how to treat bona fide discount points, charges retained by affiliates, and fees paid for outsourced origination services under the QM points and fees test.