NCSHA Comment Letter on CFPB’s Proposed Rule on the Qualified Mortgage Definition
On September 8, 2020, NCSHA submitted this letter supporting the Consumer Financial Protection Bureau’s proposal to eliminate the maximum borrower debt-to-income (DTI) ratio of 43 percent that mortgages must meet to satisfy the definition of “Qualified Mortgage” (QM) and qualify for the legal protection the definition confers. Rescinding the DTI ratio will allow many creditworthy working families to qualify for mortgage credit without lowering consumer protections. NCSHA also appreciates that the proposed rule’s new price-based threshold for meeting the QM standards is clear and easy to implement. The letter urges CFPB, when finalizing the rule, to analyze how the proposed thresholds will impact liquidity in the housing market, monitor the effects of the thresholds once the rule is implemented, and adjust the thresholds if called for.