NCSHA Comments to CFPB on Concurrent Rule Exempting HFAS from Ability-to-Repay/QM Rule

On behalf of the state Housing Finance Agencies (HFAs) it represents, the National Council of State Housing Agencies (NCSHA) appreciates the opportunity to comment on the Consumer Financial Protection Bureau’s (CFPB) January 10 proposed rule amending the Ability-to-Repay standards under the Truth in Lending Act. NCSHA commends CFPB for developing a final Ability-to-Repay rule and, within it, a Qualified Mortgage (QM) definition that will protect consumers and help to ensure that lenders and brokers follow responsible underwriting standards. We strongly support CFPB’s proposal to exempt loans originated through HFA programs from the ability-to-repay standards, which will ensure that HFAs can continue to offer low- and moderate-income borrowers responsible affordable loan products that fit their unique needs.