The CFPB is assessing the Ability to Repay rule, also known as the Qualified Mortgage rule, they released in January of 2014. Under the rule, we have a 43% ratio that essentially only applies to private industry loans and a 3% cap that really only applies to mortgage brokers because of all of the exemptions. This is your opportunity to comment. Certainly, we would recommend that they remove lender-paid compensation from the 3% cap. That would give an even playing field for all originators, that the CFPB claims to want to create. Secondly, the government loan exemption from the 43% ratio expires in 2021. The CFPB must decide in this iteration if that should be extended. Changing to a 50% DTI would be the best choice but we really need to extend the GSE/FHA/VA exemption if raising the DTI is not their choice. They also need to make certain streamline refinances remain QMs.
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