WASHINGTON (9/4/13)--Credit Union National Association staff dig deeper into a joint federal financial agency revised proposed rule on credit risk retention in this week's edition of the Regulatory Advocacy Report
The joint agency release proposes a definition of the term "qualified residential mortgage (QRM)" for purposes of creating an exemption from the risk retention requirements under the Dodd-Frank Act. The definition of QRM would be revised to be the same as the Consumer Financial Protection Bureau's definition of a qualified mortgage. This is a development that CUNA had urged.
CUNA has asked interested credit unions to comment on the proposal (See Sept. 3 News Now
story: CUNA Seeks CU Comment Call On Revised QRM Rule.)
The Regulatory Advocacy Report
provides extra details on the alternative "QM-Plus" definition outlined in the joint agency proposal.
The QM-Plus definition would serve as a more stringent alternative to the proposed QRM definition. The proposed QM-Plus requirements are:
QRMs must meet the CFPB's core criteria for QM;
QRM treatment would only be available for loans secured by one-to-four family properties that are the principle dwelling of the borrower;
QRMs must be first-lien mortgages; and
Originators would need to ensure that a given borrower is not 30 or more days overdue on any debt obligation, and had not been 60 or more days late on a payment within the past two years.
Bankruptcy and loan-to-value requirements are also outlined in the QM-Plus proposed definition.
This week's Regulatory Advocacy Report
An update on ongoing interchange litigation;
CUNA comments on a proposed National Credit Union Administration e-filing regulation; and
Details on a recent cybersecurity meeting attended by CUNA.
A resource chart with information on current CUNA comment calls is also provided in the Report
. The Regulatory Advocacy Report
also includes updated regulatory advocacy resource charts with comprehensive information on proposed and final CFPB rulemakings, and the more than 150 updated federal regulations that impact credit unions.
For this week's Regulatory Advocacy Report
, use the resource link.