The Center for Responsible Lending (CRL), The Leadership Conference on Civil and Human Rights, NAACP, National Urban League, and UnidosUS appreciate the opportunity to respond to the Consumer Financial Protection Bureau’s (CFPB or Bureau) Advance Notice of Proposed Rulemaking (ANPR) on the Qualified Mortgage (QM) definition under the Truth in Lending Act (TILA) and Ability to Repay / Qualified Mortgage regulation (ATR/QM). Our comment refers to a paper published by CRL entitled A Smarter Qualified Mortgage Can Benefit Borrowers, Taxpayers, and the Economy (July 2019). Rather than repeat information presented in the paper, the comment references where the paper discusses a topic instead. In addition, please see Appendix 1 for QM Principles.
September 16, 2019