Decades of lending have shown that low down payment lending can be successful. Excluding millions of good borrowers from the mainstream mortgage market would be a serious mistake.

CRL and six other organizations submit comments to regulators explaining why government-mandated down payments would be damaging to lower- and middle-income families and the housing market as a whole.

On August 29, 2012, CRL and several other organizations submitted a letter to federal and financial regulators opposing a government-mandated down payment requirement as part of the pending definition of “Qualified Residential Mortgages (QRMs).” Regulators are considering imposing minimum down payment requirements as part of QRM standards. While much has been written on the barriers to homeownership that would result from the 20 percent down payment requirement included in regulators’ April 2100 proposed rule, there has been less commentary on a possible 10 percent down payment.

The Center for Responsible Lending, Consumer Federation of America, and Empire Justice Center submitted comments to the Federal Housing Finance Agency on a proposed rule for the 2012-2014 Enterprise Housing Goals. "It is critical that FHFA continue to focus on its responsibility of ensuring that the Enterprises serve the entire housing market." The Enterprises can do this while fostering a liquid, competitive and strong housing market.

The Center for Responsible Lending, Consumer Federation of America and The Leadership Conference on Civil and Human Rights responded to the CFPB's request for comments on qualified mortgages. Much of the comment letter focuses on an appropriate "bright line" debt-to-income ratio standard for QMs. Setting a narrow debt-to-income ratio for QMs would unnecessarily exclude a large share of borrowers from QM protections. This letter supports setting a baseline debt-to-income ratio on QMs while also giving lenders flexibility to go above it by considering other "compensating factors" that affect a borrower's ability to handle a loan successfully.