ABA yesterday urged the Consumer Financial Protection Bureau to carefully consider costs and burdens associated with its Ability-to-Repay/Qualified Mortgage rule as it conducts a required assessment of the final rule’s effectiveness.
While ABA generally supported the bureau’s proposed assessment plan, it noted that the review should not only focus on the consumer safety objectives of the ATR rules, but also take into account whether the mortgage markets are operating transparently and efficiently and facilitating access and innovation. The association added that the CFPB’s review should thoroughly examine overall compliance costs imposed by the rule.
In addition, ABA recommended several modifications to the rule that would incentivize the expansion of safe lending activities, including a safe harbor for QM loans held in portfolio, increasing or eliminating the 43 percent debt-to-income standard, eliminating the points and fees test for QM loans and raising the threshold for compliance with the servicing rule 5,000 mortgages to 25,000 mortgages. For more information, contact ABA’s Rod Alba.