Nov 1, 2013· Comment Submitted by Robert Davis, The American Bankers Association (ABA)· HUD-2013-0090-0949
The American Bankers Association (ABA) is pleased to submit the following comments with regard to the Qualified Residential Mortgage (QRM) provisions included in the above referenced proposed rule. ABA is also a member of the Coalition for Sensible Housing Policy and is joining in the comments submitted by that Coalition and has joined with the Securities Industry and Financial Markets Association (SIFMA) and the Financial Services Roundtable (FSR) to comment on QRM and a number of other credit risk retention issues. In addition to the comments filed by the Coalition for Sensible Housing Policy and jointly with SIFMA and FSR, ABA wishes to highlight the specific points in this letter with regard to QRM.