Mortgage subservicing: What is it, and how can it work for my CU?

CFPB review of General QM rule brings uncertainty to system

April 5, 2021

The Consumer Financial Protection Bureau’s (CFPB) stated intention to review the General Qualified Mortgage (QM) rule brings uncertainty and instability to the mortgage financing system, CUNA wrote to the CFPB Monday. In February, the bureau issued a statement indicating it would review the General QM Final Rule, finalized on December 10, 2020. A proposal from the CFPB notes this intention to review and would move the mandatory compliance deadline for December’s General QM Final Rule to Oct. 1, 2022 (from the current July 1, 2021).

“The Bureau’s statement that it will review this rule and may initiate another rulemaking has a significant chilling effect on compliance efforts to implement the General QM Final Rule on the part of creditors, their vendors, and secondary market participants,” the letter reads. “It makes little sense for a credit union or a vendor to invest significant time or cost on the necessary systems, processes, and training when the Bureau has indicated an intention to alter some or all of the Final Rule prior to the mandatory compliance date.”

CUNA strongly urges the CFPB, if it does initiate another rulemaking process, to finalize an implementation period in line with these recommendations to prevent disruption of the market and to protect consumers.

This kind of incremental change promotes stability in the housing finance sector and maintains affordable access for consumers,” CUNA wrote.