CHLA Letter to CFPB: USE QM PATCH RULEMAKING TO HELP FACILITATE A GSE UTILITY MODEL

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.