April 22, 2011
What are potential risks to the Real Estate community and consumers. Some analyst have calculated the the 5% risk retention will be booked as a capital charge to the lender and securitizer which will cause a ripple effect in pricing of these loans. The mortgage interest rate increase is projected at lease 3/4 of a point to 3 points higher than today if the loan does not meet the QRM standards. 
Potential hazards of current definition of QRM: 
 When and if Fannie  Freddie go private as the current administration is pushing? 
 So think about the consumer who has a Jumbo loan and their home has lost value and cannot refinance because of LTV. 
 What about a client who had mortgage insurance and LTV is higher than 75%? 
 What about the first time buyer? FHA is now 1% upfront rolled onto balance of loan, plus 1.15% per month cost to borrowers. Current rule would not take PMI into consideration. 
 Doesnt Mortgage Insurance and additional underwriting help ensure loan quality even under higher LTVs?