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NAFCU and its members are "troubled by the growing cost of mortgage lending" due to the CFPB's ability-to-repay/qualified mortgage rule and the negative effect the rule has had on credit unions' origination volumes, profitability and member satisfaction, NAFCU told the bureau in a letter Friday.

"The rule has forced some credit unions to increase their staff and has constrained their capacity to provide non-conforming loans, which has hurt credit unions' ability to provide financial services to the underserved populations that need it the most," NAFCU Regulatory Affairs Counsel Ann Kossachev wrote in an official comment letter to the CFPB as it conducts an assessment of its ATR/QM rule.

The CFPB in May announced the assessment and its plan to issue a final report by Jan. 10, 2019.

Responding to the bureau's request, Kossachev detailed how the ATR/QM rule has increased costs for credit unions, causing some credit unions to stop their mortgage operations completely. "The CFPB's failure to recognize the unique structure of credit unions and tailor regulations accordingly has caused significantly higher compliance costs for credit unions across the country," she wrote.

The letter also offered some suggestions from NAFCU and its members. Kossachev noted that the CFPB should reconsider the expiration of the Temporary GSE (government-sponsored enterprise) QM category and make this category a permanent QM category. She added that the bureau should also provide further clarifications or modifications to the debt-to-income threshold and points-and-fees threshold.

"Such revisions are important to ensuring that credit unions' ability to provide loans and services to their members is not compromised and their access to the secondary mortgage market is not diminished," she wrote.