Among the most significant rewrites to U.S. residential-mortgage regulation in the Dodd-Frank Act1 is a requirement that regulators define “qualified mortgages” (QMs) that provide protection to originators against predatory-lending claims. The CFPB has reopened comment on this issue and, while seeking to limit views only to a circumscribed set of data issues, will surely generate broad industry and consumer views on a rule that, when finalized, strategically redefines this market. Specifically discussed in the request are data that would better permit the CFPB to define QMs that reflect long-term borrower ability to repay and support a decision between the safe-harbor and rebuttable-presumption approaches to the legal-risk safeguard resulting from QM designation.
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