Comments Due to NAFCU: Qualified Mortgage Definition Under the Truth in Lending Act (Regulation Z)
NAFCU would like to highlight the following:
- The Temporary Government Sponsored Enterprise (GSE) QM loan category (Temporary GSE QM or “GSE Patch”) expires on January 10, 2021; the Bureau is considering revisions to the definition of a General QM loan in light of the expiration.
- The Bureau is soliciting feedback on assessing a borrower’s ability-to-repay (ATR) under the General QM loan definition, including whether a debt-to-income (DTI) analysis should be included.
- In addition, the Bureau is soliciting feedback on changes to Appendix Q.
Comments due to NAFCU: August 30, 2019
Comments due to FHFA: September 13, 2019
NAFCU will send comments on behalf of its members to the NCUA by their deadline (August 30, 2019).