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NAR Comments on 3% Cap

June 6, 2014

On Thursday, June 5, 2014, NAR submitted comments on the Consumer Financial Protection Bureau's (CFPB) proposal to implement a limited cure provision for loans that exceed the 3% cap on fees and points under the Qualified Mortgage (QM) safe harbor.  If the cap is accidentally exceeded, a lender may rebate the excess to a consumer within 120 days and the loan will then qualify for the QM safe harbor.  NAR supported the cure provision with some simplifications and encouraged the CFPB to implement one for loans that exceed the 43% debt to income (DTI) cap. NAR also encouraged CFPB to put oral guidance on 3% issues in writing as well as fixing the discrimination against affiliates in the calculation of fees and points.  A final rule is expected later in the year.   

NAR Comment Letter

Kenneth Trepeta, ktrepeta@realtors.org, 202-383-1294
Charles Dawson, cdawson@realtors.org, 202-383-7522