CMC Comment on 2013 QM Proposal

  1. Conclusion

    We appreciate the CFPB’s efforts to consider the many ramifications of the definition of points and fees because that definition will greatly affect the availability of housing credit. At the same time, including loan originator compensation within the definition will not offer any consumer protection, and it will reduce consumers’ financing flexibility. We urge the CFPB to exclude loan originator compensation from the definition of points and fees as an unnecessary interference with housing finance.