CFA joins other groups urging the Consumer Financial Protection Bureau (CFPB) to rethink its pricing proposal for Qualified Mortgages (QM).  The letter strongly opposed the Bureau’s proposed use of a pricing test to define when a mortgage meets the QM test, arguing that this approach ignores congressional intent in the Dodd-Frank Act to require creditors to use apply an ability to repay test for mortgage loans that takes into account an individual borrower’s facts and circumstances.