Comment Letter: CFPB on QM Compliance Delay and GSE Patch Extension

April 6, 2021

USMI submitted a comment letter to the Consumer Financial Protection Bureau in response to its Notice of Proposed Rulemaking (NPR) to delay the mandatory compliance date of the December 2020 General Qualified Mortgage (QM) final rule and the extension of the Temporary GSE QM category (GSE Patch). In the letter, USMI discussed both the interplay between the proposed extension of the GSE Patch and the January 2021 amendments to the Preferred Stock Purchase Agreements (PSPAs) as well as the value of increased monitoring and access to mortgage underwriting data for policymakers and housing finance stakeholders. USMI urged the Bureau to work expeditiously with Treasury Secretary Janet Yellen and Federal Housing Finance Agency Director Mark Calabria to further amend the PSPAs to restore authority for the GSEs to acquire mortgages in reliance on the GSE Patch. See the full letter here.