Summary

HPN applauds the new revisions to the proposed risk retention and qualified residential
mortgage (QRM) rule. In aligning the QRM definition with the Consumer Financial Protection
Bureau’s qualified mortgage (QM) definition, regulators have responded to concerns raised in
our previous comment regarding the need to balance responsible lending with preserving
access to credit for creditworthy borrowers, including LMI and minority borrowers. In
particular, the rule eliminates the previous QRM definition’s twenty percent down-payment,
incorporates greater flexibility into underwriting requirements, and provides greater flexibility
for small lenders.
However, HPN is concerned that regulators have not explicitly exempted state and local
Housing Finance Agencies (HFAs), Treasury-certified Community Development Financial
Institutions (CDFIs), and non-profit creditors originating fewer than 200 loans annually from the
credit risk retention rule, in line with the exemption that was amended to the CFPB Ability-toRepay/QM
rule in May 2013. 

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