As required by the Dodd-Frank Act, the CFPB has taken what in the U.S. is the unusual step of asking for public input on how to think about a key mortgage-finance rule, an effort that could lead to substantive change under this CFPB director or a successor. Many in the industry have argued that these mortgage rules – perhaps most importantly the one stipulating what is a “qualified mortgage” (QM) on which this RFI is focused – have adversely affected housing-finance availability for all but the best-qualified borrowers. Key aspects of the QM rule – e.g., the current GSE exemption – are also set for changes that could well alter the rule’s impact in problematic ways unless this RFI advances changes in either the QM or GSE policy.
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