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Joint Letter to Regulators on Elements of "Qualified Residential Mortgages"

January 25, 2011
Mortgage Lending
Comment Letter

In this letter to federal regulators, CRL and other national civil rights, labor and consumer organizations share their views on the regulation of securitizers of residential mortgage loans - specifically "qualified residential mortgages" or QRMs. The two points made by the letter:

1. Securitized loans should meet basic servicing standards to prevent unnecessary foreclosures

2. QRM standards should not include downpayment requirements that penalize responsible, creditworthy borrowers who lack the wealth necessary for a large down payment.

Signers to this comment letter were the following:

AFL?CIO
Americans for Financial Reform
Leadership Conference on Civil Rights rhoods
NAACP
National Association of Neighborhoods
National Council of La Raza
National Fair Housing Alliance
National People's Action
InternationalService Employee Union
Center for Responsible Lending
Consumer Action
National Association of Consumer Advocates
National Consumer Law Center (on behalf of its low income clients)