When we looked at the Cordray CFPB’s request for views on the QM rule, we noted that it showed no interest in QM revisions but also that this could quickly change when the Trump Administration took over the agency.  Under its new director, Kathy Kraninger, the CFPB is taking quite a different view on the QM, looking now to early action on the GSE exemption and to cost-benefit analyses that could lead to a whole new set of QM criteria.  The Friday report is an exhaustive study often of minor details based in many places on marginal data, but it nonetheless shows that the QM without a GSE exemption would be a very different rule with sweeping impact on low-and-moderate income households.

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