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Comments to the Consumer Financial Protection Bureau RE: Ability to Repay Standards under the Truth in Lending Act (Regulation Z)

February 25, 2013
Mortgage Lending

CRL and allied organizations maintain that CFPB's proposal addresses two issues critical to the future of safe, sustainable, and affordable access to mortgage credit. First, it considers how to define compensation for the purpose of calculating the points and fees cap contained in the qualified mortgage definition. Second, it proposes a series of exemptions for specialized lending programs and financial institutions that play an important role in ensuring broad access to safe and affordable credit. This comment letter discusses both of these aspects of the concurrent proposal.