NAFCU seeks input on point-and-fees, DTI issues
May 16, 2014 – NAFCU is asking member credit unions to provide their input by May 26 to the association’s official comment on a CFPB proposal that would allow refunds of excess points and fees charged without violating the qualified mortgage rule.
The proposal would, in limited circumstances, allow a lender that inadvertently exceeded the rule’s 3 percent points-and-fees cap to refund the excess and still meet the legal requirements for a QM.
CFPB is also seeking comment on whether it should provide similar authority regarding the QM debt-to-income limit. That is, should it permit a post-consummation correction or cure for loans originated in good faith but exceeding the DTI limit. It also wants input on the effects of its rules on larger lenders that do not meet the definition of a small creditor.
CFPB is taking comments on the point-and-fees issue until June 5 and on the DTI issue and “small creditor” issue until July 7.
NAFCU members are encouraged to download the association’s Regulatory Alert (member only) and to submit comments online.
Regulatory Alert 14-EA-09 (member only)
Submit comments online