CFA, NCLC and Other Consumer Groups’ Comments on CFPB Request for Comment on the ATR/QM Lookback

The ability-to-repay rule has made a significant, positive impact in the lives of homeowners and has contributed to the restoration of a functioning mortgage market. This was crucial after the Great Recession rolled back a generation of progress on asset and wealth building through homeownership while decimating the economy. While further improvements to the rule are needed, the rule has restored common-sense principles to the origination market and has done so without restricting access to credit. In these comments, we offer a number of recommendations to strengthen the rule.

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