mr. emerson? >> yeah, i think when you evaluate the 3% test and take a look at lower load amounts specifically in the range of 100 to $150,000 and there are going to be folks that fall into the bucket that will fall outside of the 3% test, therefore falling outside of the qm rule. >> being from memphis, i serve in a community that's over 60% african-american, and a lot of loans, 11%, affects a major part of these individuals. now my procedures based on this new rule state prices on qm mortgages to address the risk. i don't want to -- it's just not going to serve my community if i have to kmarj somebody for a mortgage i would have given them last year because there's a rule in place. if you find a lower income borrower who doesn't mean the qm standard are you going to charge them a higher interest rate and higher fees? >> i would not go any higher. the problem is on my balance sheet i can only hold so much. if i do say okay, we're going to go full blown into nonqualified mortgages, it's a limited t

mr. emerson and mr. weickenand, it sounds like amendments are continuing to improve qm and you all are happy with it. my question is timing. with new clarifications as late as last fall, does that timing put you -- do you feel like you need an extension to ensure that you get it right or do you think that that would just put you at a disadvantage? >> we're a small shop. i've got 68 full-time equivalent employees and seven offices we have to manage. we have all hands on deck today from our mortgage lenders, our commercial lenders trying to figure out everything we need to do with the new mortgage regulations. more time would be very helpful. we also have to see how software vendors -- they may put in fixes but we need to make sure we know how that integrates. multisoftwa software vendors ha integrate with one another. it's difficult trying to do anything else other than trying to comply with qm and regulations that go with it. >> do you think that holds true for all community bankers? >> yes, i believe it