Within the escrow requirements, the Dodd-Frank Act did provide for an exemption for banks in rural or underserved areas, but I think broader exemptions for community banks should be considered. The definitions of qualified mortgages (QMs) and qualified residential mortgages (QRMs) could have a profound effect on the mortgage terms offered and the underwriting conditions for all banks.
To the extent that these definitions constrain community bankers from using their experience with the cash flows from a small business customer or their knowledge of local real estate markets to customize a loan for an "irregular" situation, such loans may not be made.