CUNA
submitted comments to the CFPB in response to their request for comment
regarding their interim final rule titled, “Qualified Mortgage (QM) Definition
Under the Truth in Lending Act (Regulation Z): Extension of Sunset Date.” This
rule would amend
Regulation Z to replace the sunset date of the Temporary GSE QM loan definition
with a provision that extends the Temporary GSE QM loan definition to expire
upon the effective date of final amendments to the General QM loan definition.
“CUNA supports the extension
as a prudent and necessary action to ensure consumers’ continued access to
affordable mortgage loans while the Bureau completes its rulemaking on the
General QM definition,”
the letter states. “We strongly believe the CFPB should avoid
gaps in QM coverage that would disadvantage borrowers and create uncertainty in
the nation’s economically vital mortgage lending market.”
The letter also offers
recommendations and considerations, including adopting a longer extension or
transition period to ensure that the effective date for the new QM
definition allows for a gradual transition period as credit unions come into
compliance with the new QM regime.
CUNA will continue
to work with the CFPB to ensure credit unions members continue to have access
to responsible, affordable mortgage loans from community-based lenders.