On October 1, SFA submitted a response to the Consumer Financial Protection Bureau on their Notice of Proposed Rulemaking for QM Loan Seasoning. This comes after SFA had previously submitted responses on the CFPB’s Patch Extension NPRM and General QM NPRM. The Loan Seasoning NPRM would allow a loan that is held by the originator for a certain time period, and where the borrower makes on-time payments during that time period, to be deemed a Qualified Mortgage.
SFA’s comments recommend that CFPB clarify that a loan which has achieved QM status by any means will not lose that designation in the future, i.e., once a QM loan, always a QM loan. Moreover, SFA recommends that the only factor be whether the borrower makes the requisite number of on-time payments, regardless of who owns the loan. This will increase liquidity without undue barriers that restrict access to credit for borrowers getting mortgages from different kinds of lenders.
If you have questions or would like to be added to SFA’s ATR Task Force, please contact [email protected].