On Monday August 10, 2020 the Structured Finance Association (SFA) submitted a letter to the Consumer Financial Protection Bureau (CFPB) in response to the Notice of Proposed Rulemaking (NPR) on extending the Qualified Mortgage (QM) Patch. In the NPR, the CFPB proposed extending the date of the scheduled expiration of the QM Patch past its current deadline of January 2021 until the new QM regulation is implemented. SFA agreed with CFPB’s proposal to extend the Patch past its current expiration date, and recommended an overlap period of 6 month where both the current QM rule and any new QM rule are in place concurrently, which will aid in the transition process and help minimize any disruptions.

For more information on the CFPB’s efforts on the Ability to Repay/Qualified Mortgage Rule (ATR/QM), or to join SFA’s ATR/QM Task Force, please contact [email protected].