Originations Is 11 (or 8, or 6) months a long time or a very short time to prepare for full implementation of QM, HOEPA, appraisal requirements and other CFPB rules? Published April 8, 2013 1:20 PM | Updated January 6, 2020 1:02 PM 1:10 Facebook Twitter LinkedIn Email 01_Roger_q4_2