Advocacy Comments on CFPB Notice of Assessment of Ability-to-Repay/Qualified Mortgage Rule and Request for Public Comment
July 28, 2017
Notice of Assessment of Ability-to-Repay/Qualified Mortgage Rule and Request for Public Comment
The Office of Advocacy of the U.S. Small Business Administration (Advocacy) submits these comments on the Consumer Financial Protection Bureau (CFPB or the Bureau) Request for Information Regarding 2013 Ability-to-Repay/Qualified Mortgage (ATR/QM) Assessment.[1] Advocacy encourages the CFPB to consider less burdensome alternatives for small entities as part of the assessment process. Specifically, Advocacy believes that the assessment of the rule would benefit from a comprehensive study to determine the economic impact that the QM rule has had on small entities and further outreach to small entities to develop less costly alternatives.
