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Comments on the Qualified-Mortgage Rule Under the Truth in Lending Act (Regulation Z)

August 16, 2017
Mortgage Lending
Comment Letter

These comments respond to the Consumer Financial Protection Bureau’s proposed amendments to the qualified-mortgage (QM) rule as it relates to 1) the importance of the QM rule, 2) why the constrained lending environment is due to factors other than QM, and 3) why they should be addressed rather than weakening QM, 4) our analysis of CFPB’s proposed evaluation, and 5) possible responsible changes to the Ability-to-Repay/QM rules.