August 30, 2013
As a mortgage lender I believe that simplicity has taken a back seat to special interest groups in the development of all mortgage lending rules we have seen over the last few years. Ultimately the group that suffers the most from these byzantine rules is the consumer both in cost and clarity. And,ironically, one of the justifications for all these rule changes we have seen is to make mortgage lending easier for the consumer to understand.
That said, whatever the final rule looks like, QRM and QM need to be identical. Even a divided Congress can sometimes pass a bill everyone can agree upon. If Congress can do it, the CFPB and the other regulatory agencies can put their collective heads together and do it.