Specifically, the Coalition opposes the addition of stringent down payment and otherrnrestrictive requirements to the QRM definition which they say will ultimately limit the abilityrnof private capital to reach lowerrnincomernhouseholds and first-time buyers. The QRM, they maintain, should not be more restrictive than QM.</p

The Coalitionrnstates that the QM definition provides strong underwriting,rndocumentation and product standards that demonstrably lower the risk ofrndefaults consistent with the statutory requirements for the QRM. Synchronizingrnthe QRM definition with the QM would ensure that strongrnincentives for safe and sound lendingrnare in place, while not impairingrnthe return ofrnprivate capitalrntornall segments of thernmortgage finance market.  Also, they say the QM featuresrnarernentirely consistent with the investor protection goals ofrnSection 941 of the Dodd-Frank Act, which limits the QRM exemption from risk retention to loans with “product features that historicalrnloan performance datarnindicate result in a lower risk of default.”</p

The letter was sent to the heads of thernOffice of Comptroller of the Currency, the Federal Deposit InsurancernCorporation, Department of Housing and Urban Affairs, The Federal Reserve, the Securitiesrnand Exchange Commission, and the CFPB.</p

The Coalition’s membership is composedrnof national and state associations representing banking, real estate, title,rnbuilding, consumer, and other interest groups.

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