The Consumer Financial Protection Bureau (CFPB) recently issued an Advanced Notice of Public Rulemaking (ANPR) on the Ability to Repay-Qualified Mortgage (ATR-QM) Rule, seeking feedback from stakeholders and market participants on the expiration of the GSE QM “Patch”, among other aspects of the ATR-QM rule. Based on SFA’s unique position of representing the entire securitization industry—from lenders and issuers to investors—SFA undertook a survey of its membership regarding the potential implications of the planned expiration of the QM Patch and ATR-QM rule. The results of this survey, while not attributable to any specific member organization, will help inform SFA’s advocacy on this issue.
View survey results.
In conjunction with the QM Symposium hosted by SFA and Andrew Davidson & Co., as well as SFA’s ongoing QM Task Force meetings and calls, this survey provides the basis upon which SFA will respond to the CFPB’s ANPR. Rather than submit a proposal that seeks to address every question or issue raised as a result of the ANPR, SFA’s response will focus on themes and principles garnered from members. The response will note where there appears to be areas of broad agreement, as well as where there are currently differences of opinion on questions like how to distinguish QM from non-QM loans, whether and how CFPB provides guidelines for verifying and documenting income, and the role of the GSEs. In the weeks ahead, SFA will continue to convene its members in an effort to develop a framework of a proposal that seeks to address all of these concerns, and will continue to work with CFPB as they develop a formal notice and rulemaking process on the ATR-QM Rule.
If you have questions or feedback you would like to submit, or if you would like to join the QM Task Force, please email [email protected]. We would like to extend our thanks to the members who have contributed to the survey, and look forward to working with you on this important initiative.