Aug. 14, 2012 – NAFCU Regulatory Affairs Counsel Dillon Shea and COMSTAR FCU President and CEO Vicki Johnston met Monday with Consumer Financial Protection Bureau officials to provide the association’s perspective on the agency’s qualified mortgage rulemaking proposal.
The discussion, which included a number of other industry groups, focused on several important aspects of the CFPB’s proposed qualified mortgage rule.
The CFPB is currently considering whether the qualified mortgage rule should provide lenders safe harbor, or merely a rebuttable presumption of compliance. NAFCU continues to press for a safe harbor as the rebuttable presumption of compliance would create significant new litigation issues, increase the cost of credit for all borrowers and result in a tightening of the credit market.
NAFCU believes that providing lenders with safe harbor would also ensure that the largest number of borrowers possible will benefit from the safest and most affordable options for sustainable credit available through the QM.
The CFPB has yet to indicate when it expects to finalize its QM rule. The statutory deadline is January 2013.