Removing Barriers Blog

Comments Submitted to CFPB on QM Definition of TILA: Extension of Sunset Date

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.