Removing Barriers Blog

Comments submitted to CFPB re: compliance deadline for QM
Posted April 05, 2021 by CUNA Advocacy

CUNA filed a comment letter with the Consumer Financial Protection Bureau (CFPB) in response to their proposal to delay the mandatory compliance deadline related to the General Qualified Mortgage(QM) Final Rule issued last December. The letter states “Neither credit unions nor their members will suffer from temporarily having access to multiple avenues to QM protection. However, the delay combined with the Bureau's stated intention to review the rule has its own consequences.” The letter goes on to detail how the Bureau's stated intention to review and potentially repropose a new General QM definition injects uncertainty and instability into the mortgage financing system by chilling implementation efforts of December's Final Rule. We urge the Bureau to be transparent about its review of the Final Rule and to allow a meaningful implementation period in line with our previous asks if it decides to do further rulemaking regarding the General QM definition.