Credit Union National Association
CFPBNonrulemakingCFPB-2019-0039

Qualified Mortgage Definition Under the Truth in Lending Act (Regulation Z)

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Credit Union National Association filings
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Credit Union National Association filed 1 comment on this docket between Sep 17, 2019 and Sep 17, 2019. 30 other organizations filed here. The comment window closed 2507d ago.

What Credit Union National Association filed (1)

Sep 17, 2019· Comment Submitted by Mitria Wilson, Credit Union National Association· CFPB-2019-0039-0037

Attached, please find the following comment on behalf of CUNA-the Credit Union National Association.

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’’ obtain certain protections from liability. One category of qualified mortgages (QMs) is loans that are eligible for purchase or guarantee by either the Federal National Mortgage Association (Fannie Mae) or the Federal Home Loan Mortgage Corporation (Freddie Mac). Under Regulation Z, this category of QMs (Temporary GSE QM loans) is scheduled to expire no later than January 10, 2021. The Bureau currently plans to allow the Temporary GSE QM loan category to expire in January 2021 or after a short extension, if necessary, to facilitate a smooth and orderly transition away from the Temporary GSE QM loan category. The Bureau is considering whether to propose revisions to Regulation Z’s general qualified mortgage definition in light of that planned expiration and is issuing this ANPR to request information about possible revisions.

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