Association Survey on QM-designation Deadline Approaching

The Cooperative Credit Union Association, Inc. is seeking your views on a new notice from the Consumer Financial Protection Bureau regarding the definition of “qualified mortgages” under Regulation Z, Truth-in-Lending Act (TILA) and Ability to Repay (ATR)/Qualified Mortgages (QM) Rules.

Under TILA, creditors are required to assess a mortgage borrower’s ATR using credit history, income, debt-to-income ratio or residual income, employment status and other factors.

Creditors are presumed to have assessed a borrower’s ATR if the loan and loan process meet QM requirements under Regulation Z. The rule provides categories of QMs, such as general QMs that meet debt-to-income ratio requirements addressed in Appendix Q to the rule and temporary QMs that are eligible for purchase by Fannie Mae or Freddie Mac (GSEs) that may have higher DTI limits than general QM loans.

It is the treatment of the temporary QM-designation that is the focus of the CFPB’s notice, though some other related issues will also be under review by the agency.

The full proposal may be read HERE.

The Association participated on a call with the CFPB in July, prior to the publication of the notice in the Federal Register, and was briefed on key aspects of the issues involved, and the Association will be filing a comment letter.  

This survey should take no more than 15 minutes of your time. We would appreciate your response by September 16 so that we may include your concerns in our letter to the agency. Thank you in advance for your participation.