Delaying the mandatory compliance date of the new QM rules could “foster disruptive market confusion and complicate bank compliance efforts considerably,” the American Bankers Association said in a comment letter to the Consumer Financial Protection Bureau yesterday.
ABA’s comments came in response to a recent proposal to extend the mandatory compliance date from July 1 to Oct. 1, 2022, and extend the temporary “GSE patch” until the new mandatory compliance date or until Fannie Mae and Freddie Mac exit conservatorship, whichever comes first. The CFPB said it would also conduct a review of the new QM rules.
“[T]he clear and sensible reforms contained in the new General QM provisions are endorsed by a very broad consensus of interests, is more inclusive of the types of communities the bureau wants to see served, and America’s banks are confident that they can continue, and even expand, lending operations to meet the needs of an evolving housing market, without delays,” ABA said. The association added that “any postponement of the compliance date would disrupt and retard the efforts currently underway by third parties and internal staff to redesign QM compliance systems.”
ABA echoed these sentiments in a separate letter submitted in coordination with a broad coalition of consumer advocacy and financial and housing trade organizations, emphasizing that the new QM framework “provides the best solution available” to expand fair and equitable access to credit, maintain existing safe product features and provide an effective replacement for the GSE patch, “while retaining the core consumer protections provided by the QM product safeguards and requirements for lenders to consider and verify debts and income.”
