Structured Finance Association Logo

Menu
  • SFA on the Issues
    • Back
    • Overview
    • Committees and Task Forces
    • COVID-19: Supporting Consumers & Businesses
    • Capital & Other Bank Regulations
    • Disclosure & Reporting
    • ESG Institute
    • Global Initiatives
    • Housing Finance
    • LIBOR Transition
    • Market Structure & Dynamics
    • Research Corner
    • Structured Finance in the Courts
  • About Securitization
  • News
    • Back
    • Overview
    • Press Releases
    • Industry News
    • SFA News
    • Newsletter Sign Up
  • Events
  • Diversity, Equity, and Inclusion Hub
  • Women in Securitization
  • Structured Finance Coalition
  • Structured Finance Foundation
  • About Us
    • Back
    • Overview
    • Board of Directors
    • Our Team
    • Our Members
    • Committees and Task Forces
  • Join Membership
    • About Membership
    • Join
  • Blog
  • Multimedia Library
  • Make a Payment
  • Careers

COVID-19 Resources

Learn how the Structured Finance Association and our members are supporting consumers and businesses during this global pandemic.

Learn More

    SFA: Industry SRO Can Help Define ATR Standards for Mortgages and Reduce Costs

    Download SFA's Full Response

    On Tuesday September 8, SFA submitted a response to the CFPB’s NPRM on the proposed General Qualified Mortgage (QM) definition. SFA had previously responded to the CFPB’s ANPR on the topic of QM and Ability to Repay (ATR), and this NPRM response builds off our previous efforts. SFA also submitted a response to the CFPB on extending the QM Patch past its currently-scheduled expiration date of January 2021. SFA members have a wide range of views on the proposed use of pricing to determine whether a loan is a QM. Notably, SFA members have divergent views on the use of the spread between the APR of a particular loan and the Average Prime Offer Rate (APOR) as a means of determining whether that loan receives the regulatory benefit of being a QM, which provides safe harbor from subsequent ATR claims and defenses.

    Given the divergence of our members’ views, SFA has convened representatives from across the industry to form an ATR Task Force to determine whether and how the industry can fulfill the statutory mandates that gave rise to the ATR/QM regulatory regime, while providing dynamism and innovation within the mortgage space. SFA’s ATR Task Force is chaired by industry leaders who are highly renowned and deeply involved at every stage of the securitization process in both the QM and non-QM markets.

    If you are interested in learning more about the letter or joining the SFA ATR Task Force, please contact Dallin Merrill ([email protected])

    Click here to read SFA’s response to the CFPB NPRM on General QM Definition

    Related

    SFA submits response to CFPB on extending the QM Patch until new rule is in place, and recommends a 6-month overlap transition period.

    SFA QM Symposium Key Takeaways

    Structured Finance Association QM Survey Responses

    SFA Releases Summary of Treasury Housing Report

    Securitization Alliance logo
    • Resources
    • Membership
    • Make a Payment
    • Join
    • Newsletter Sign Up
    • Structured Finance Coalition
    • Foundation
    • About Securitization
    • Careers
    • Contact Us
    • SFA on the Issues
    • About Securitization
    • News
    • Events
    • Diversity, Equity, and Inclusion Hub
    • Women in Securitization
    • Structured Finance Coalition
    • Structured Finance Foundation
    • About Us

    Structured Finance Association

    1776 I Street NW Suite 501

    Washington, DC 20006