The final rule to implement the ability-to-repay requirements was published by the Consumer Financial Protection Bureau (CFPB) in January 2013. The final rule went into effect in January 2014.
NAR supports a definition of QM and fees and points that promotes mortgage liquidity and availability. The QM should be broad based and cover a wide range of traditionally safe products and reliable underwriting criteria and should not discriminate against lenders with affiliates. NAR supports adjustments to the QM rule should its implementation result in significantly reduced access to credit or increased costs to consumers.
A definition of QM that only includes fees and points charged directly to the consumer will promote liquidity and consumer choice. Also, CFPB should be flexible and make adjustments to such things as 43% DTI cap if it is shown that access to credit has been reduced or has become unduly costly.
NAR issued comments and advocated for significant changes in the definition of fees and points to ensure consumer access and greater choice amongst mortgage providers. NAR is also seeking legislative changes to reduce discrimination against affiliates.