As we noted yesterday in our in-depth analysis, the banking agencies, SEC, FHFA and HUD have opened a review of the QRM as required by law. However, the cursory nature of the inquiry suggests that, despite Treasury’s 2017 recommendation that the QRM be revised or even repealed, the Administration now plans indirectly to attack the QRM by changing the QM, not by reopening the battles that delayed the final QRM rule for at least four years.
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