As detailed in our in-depth analysis of the CFPB’s proposal to remove the QM patch, we think it’s here to stay for a while. Although the NPR fulfills Director Kraninger’s commitment to switch the general QM definition from DTIs to pricing, the proposal is by the Bureau’s own reckoning “preliminary” and by ours often tentative and even contradictory. The CFPB has set itself an ambitious schedule to finalize the new definition and lift the patch by the beginning of the second quarter of 2021.
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