Although the CFPB on Thursday issued an ANPR seeking views on the QM patch, it didn’t invite them on the over-arching question confronting the agency:  whether to extend the GSE patch for long enough that no one need worry about it.  Reflecting the Administration’s hard-nosed view about shrinking the GSEs’ footprint, the ANPR is unambiguous that the patch will be pulled by January 20, 2021 or, if it’s extended, only for a short period to calm the industry’s nerves.  That these will rise to fever-pitch is evident about the variations possible for a new QM that would then define not only the roles of the GSEs and FHA, but also what types of mortgages are on offer across the U.S. housing-finance system.

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