The Credit Union National Association (CUNA) posted a Final Rule Analysis on the Consumer Financial Protection Bureau's (CFPB) Ability-to-Repay and Qualified Mortgages rule. Of significance, the CUNA Final Rule Analysis includes a quick summary and a new section regarding “CUNA’s Initial Take on the Impact of the Rule.” In that section, we briefly address some positive issues as well as concerns about the implementation of the rule. For example, we discuss the qualified mortgage standards and the legal protections that the CFPB intends creditors will receive by issuing QMs and the level of protection they will receive for certain other mortgage loans.
They also address issues such as the complexity of certain aspects of the rule, including the use of Appendix Q which provides standards and guidance for complying the regulation. CUNA intends to include more information about their initial reaction to final rules in all future CUNA Final Regulatory Analyses. The day after the CFPB issued the new Ability to Repay/Qualified Mortgage Rule, January 10, CUNA posted on the CUNA Regulatory Advocacy website a healthy summary of the rule. The document is available here.