Removing Barriers Blog

CUNA Offers Suggestions on CFPB’s Assessment of ATR and QM Rule
Posted July 31,2017 by CUNA Advocacy

CUNA’s Senior Director of Advocacy and Counsel, Luke Martone, sent a letter to the CFPB in response to its Request for Information (RFI) on its proposed assessment of the Ability-to-Repay and Qualified Mortgage Rule (ATR/QM Rule). 

In the letter, CUNA includes a number of suggestions on how the CFPB could improve the ATR/QM rule.  The letter goes into further detail on each of the following areas:  

  • Loans Held in Portfolio 

  • Extension of Small Creditor Exception 

  • Define  “Residual Income” 

  • Cure Provision for a Points and Fees Overage 

Prior to the financial crisis, not all lenders evaluated a borrower’s ability to repay and unfortunately this was one of the factors that led to the collapse of the housing market and the many bailouts that followed.  Once Congress passed the Dodd-Frank Act, new standards in mortgage lending including the ATR/QM Rule was implemented.  

While credit unions generally did not participate in the risky behavior that contributed to the housing crisis, they have had to comply with the new rules and regulations created in response.  Unfortunately, compliance with these rules is often overly burdensome and difficult for credit unions and community financial institutions.  

Also mentioned in the letter was a reminder about the information CUNA’s CEO, Jim Nussle, sent to Director Cordray where he highlights the ways the CFPB’s rulemakings have adversely affected the way credit unions operate and serve their members, and offers suggestions to improve these rules.  

CUNA applauds the CFPB for taking the time to reevaluate and accept constructive feedback on the ATR/QM rule.  CUNA will continue to advocate on behalf of America’s credit unions and their 110 million members in order to allow credit unions to better serve their members.