WASHINGTON (6/10/13)--Credit unions are asked to provide details on what actions they plan to take as a result of the Consumer Financial Protection Bureau's pending ability-to-repay and qualified mortgage (QM) rules through a new Credit Union National Association survey.
In the survey, CUNA asks credit unions to estimate what percentage of their loan volume falls outside of the QM loan definition. Credit unions can also suggest ways the CFPB could adjust the rule to provide greater flexibility.
The survey also seeks general credit union contact information and asset size details.
CUNA has asked that credit unions complete the survey by June 14. For the full survey, use the resource link.
The CFPB issued standards to define a "qualified mortgage" under the agency's "ability to repay" rules in January. The rule amended Regulation Z, which implements the Truth in Lending Act, to require creditors to make a reasonable, good faith determination of a consumer's ability to repay any consumer credit transaction secured by a dwelling (excluding an open-end credit plan, timeshare plan, reverse mortgage, or temporary loan). It also establishes certain protections from liability under this requirement for "qualified mortgages."
The rule provides credit unions and other creditors that follow the QM standards with a "safe harbor" for compliance with the ATR provisions. Creditors will be entitled to greater legal protection for QMs than for other mortgage loans should the creditor be sued by a consumer for noncompliance with the ability to repay provisions.