Qualified Mortgage Definition under the Truth in Lending Act (Regulation Z): Seasoned QM Loan Definition

12 organizations filed 13 public comments on Qualified Mortgage Definition under the Truth in Lending Act (Regulation Z): Seasoned QM Loan Definition, at the Consumer Financial Protection Bureau. The comment window closed 2126d ago.

Abstract

With certain exceptions, Regulation Z requires creditors to make a reasonable, good faith determination of a consumer's ability to repay any residential mortgage loan, and loans that meet Regulation Z's requirements for “qualified mortgages” (QMs) obtain certain protections from liability. Regulation Z contains several categories of QMs, including the General QM category and a temporary category (Temporary GSE QM loans) of loans that are eligible for purchase or guarantee by government-sponsored enterprises (GSEs) while they are operating under the conservatorship or receivership of the Federal Housing Finance Agency (FHFA). The Bureau of Consumer Financial Protection (Bureau) is issuing this proposal to create a new category of QMs (Seasoned QMs) for first-lien, fixed-rate covered transactions that have met certain performance requirements over a 36-month seasoning period, are held in portfolio until the end of the seasoning period, comply with general restrictions on product features and points and fees, and meet certain underwriting requirements. The Bureau's primary objective with this proposal is to ensure access to responsible, affordable mortgage credit by adding a Seasoned QM definition to the existing QM definitions.

Commenters (12)

• Consumer Federation of Americatrade assoc.

  2 filings · confidence 85%
• Alaska USA Federal Credit Unionunverified attribution

  1 filing · confidence 70%
• Ex parte submission by American Enterprise Institutetrade assoc.

  1 filing · confidence 85%
• Heartland Credit Union Associationtrade assoc.

  1 filing · confidence 85%
• Housing Policy Counciltrade assoc.

  1 filing · confidence 85%
• Indiana Credit Union Leaguetrade assoc.

  1 filing · confidence 85%
• Manufactured Housing Institutetrade assoc.

  1 filing · confidence 85%
• Mortgage Bankers Associationtrade assoc.

  1 filing · confidence 97%
• National Association of Home Builderstrade assoc.

  1 filing · confidence 97%
• National Association of REALTORStrade assoc.

  1 filing · confidence 85%
• SchoolsFirst Federal Credit Unionunverified attribution

  1 filing · confidence 70%
• Wisconsin Bankers Associationtrade assoc.

  1 filing · confidence 97%