CHLA Joins Broad Coalition in CFPB Letter Outlining Proposal to Preserve QM Ability to Repay, With Appropriate Flexibility
CHLA joined with a broad coalition including the National Association of Realtors, consumer groups, USMI, and other small lender groups in offering a proposal to retain essential elements of the QM Ability to Repay standard, but with a more flexible Debt to Income (DTI) which includes other underwriting criteria in the form of Compensating Factors
The Community Home Lenders Association wrote FHFA and the Treasury Department to express strong support for the proposal in the Administration’s housing finance reform plan to make small lender GSE parity permanent, as part of a revision of the Preferred Stock Purchase Agreements (PSPA).
In a novel approach to creating a Utility Model for the GSEs, CHLA suggested in a letter to the CFPB that the QM rule to be used to give FHFA authority to regulate mortgage loan standards for Fannie and Freddie when they exit conservatorship. The letter also stressed the critical importance of not letting the QM Patch expire without a more flexible replacement.
CHLA today released its updated GSE reform plan, following the administrative approach to GSE reform CHLA has been advocating for 5 years. Citing the substantial reforms accomplished to date, CHLA called on FHFA and Treasury to finish the task by ending the GSE Profit Sweep, finalizing a capital rule, and carrying out a Capital Restoration Plan, that results in an end to the GSEs’ conservatorship.
CHLA submitted a comment letter to Ginnie Mae, arguing that Ginnie Mae should not stress test smaller IMB issuers, as stress testing would not accurately measure smaller issuer risk, would undermine consumer access to credit, and would increase issuer concentration. The letter drew heavily from CHLA’s January “Report on Ginnie Mae.”
In a formal comment letter to Ginnie Mae, CHLA makes the case that FHA Life of Loan premiums drives borrowers to refinance out of FHA loans – a major contributing factor to an acceleration in Ginnie Mae prepayment speeds, which are harmful to the program.
CHLA submitted a detailed letter to Ginnie Mae asking it to scrap the proposed increased financial requirements and risk-based capital rule – or rework them
Bill Cosgrove highlights key findings from CHLA’s recently released IMB Report – explaining how IMBs have become a dominant mortgage force, lead in lending to
In a joint letter to Treasury Secretary Yellen and new Acting FHFA Director Sandra Thompson just hours after she was appointed, CHLA presses once again