Trades to CFPB: Eliminating debt-to-income requirement preserves access to credit

September 9, 2019


September 9, 2019 

Washington, DC 

Credit Union National Association (CUNA) joined with trade organizations urging the Consumer Financial Protection Bureau (CFPB) to retain its Qualified Mortgage (QM) safe harbor and product features but remove the debt-to-income (DTI) requirement for prime and near-prime loans when the government-sponsored enterprises’ (GSEs).  

The Temporary GSE QM, a category of QM eligible for purchase by Fannie Mae or Freddie Mac, is scheduled to expire in January 2021 or after a short extension. The CFPB issued an advance notice of proposed rulemaking on whether to propose revisions to the definition of QM in light of the planned expiration. 

CUNA and the trades propose the following to coincide with any possible expiration of the Temporary GSE QM, to preserve access to sustainable loans for creditworthy borrowers and avoid market disruption:  

  • Eliminate from the general QM category the DTI ratio requirement and the associated Appendix question 1.  
  • Maintain and enhance the existing ability-to-repay (ATR) regulatory language; and  
  • Maintain the existing QM statutory safe product restrictions that prohibit certain risky loan features and clarify provisions related to documentation and verification of income. 

“We believe the consensus ideas that our broad coalition has outlined can help the Bureau craft a forward-thinking QM definition that embraces the technological advances and innovation in the mortgage finance industry,” the letter reads. “These considerations would also recognize the rapidly transforming nature of our increasingly diverse economy and would help a new generation achieve homeownership.” 

CUNA continues to believe that lenders should have greater flexibility in determining whether consumers can satisfy ability-to-repay requirements to ensure and preserve responsible access to mortgage credit for credit union members. 

Read the letter in full here 


About CUNA:        
Credit Union National Association (CUNA) is the only national association that advocates on behalf of all of America’s credit unions, which are owned by 115 million consumer members. CUNA, along with its network of affiliated state credit union leagues, delivers unwavering advocacy, continuous professional growth and operational confidence to protect the best interests of all credit unions. For more information about CUNA, visit To find your nearest credit union, visit  


Lauren Williams      
CUNA Communications