CDFI Loans and Ability-to-Repay/Qualified Mortgages Rule

Question - My credit union is a Community Development Financial Institution (CDFI). We have created an Ability-to-Repay/Qualified Mortgages (ATR/QM) policy and have acknowledged that fact. We have also stated that since we are a CDFI, we are not required to meet the ATR requirements. Is it accurate to say that the credit union’s real estate loans are automatically deemed QMs since we are exempt from ATR as a CDFI?

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