Consumers with lower credit scores often also have low down payments when purchasing a home. As a result, fees for mortgage insurance are added to payments. In these comments, CRL argues for these consumers, citing how higher fees would be another barrier to successful homeownership. Additionally, with the enactment of new mortgage rules, notably QM (Qualified Mortgages), determining an ability- to- repay mortgages is now a threshold standard. QM remains a key remedy to the risk of poor underwriting and toxic loans that created the nation's housing crisis.

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