On September 8, BPI joined a joint coalition comment letter responding to the CFPB’s NPR regarding changes to the General Qualified Mortgage (QM) definition. These definitions help to ensure consumer access to affordable and sustainable mortgage credit, which BPI along with the eleven other signatories firmly support. The letter supports the agency’s decision to remove from the QM definition the fixed debt-to-income ratio requirement for prime and near-prime loans, which will help avoid disruptions resulting from the expiration of the temporary Government Sponsored Enterprise (GSE) Patch. The coalition further encouraged the agency to consider including no presumption or inferences relating to fair housing/fair lending, an increase in the Safe Harbor rate spread threshold, an increase to the overall QM cap, and an alternative treatment for short-reset adjustable-rate mortgages (“ARMs”).
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