Is QM=QRM QED?
Admittedly doing a bit of speed-reading, we have reviewed the 1,759 comment letters filed so far with the regulators on the revised risk-retention proposal. The consensus around QM being the new QRM is striking, with the vast majority of commenters supporting the proposed approach and strongly protesting the QM-plus option it also contained. However, we still expect the final regulation to include a downpayment kicker to the QM criterion.
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