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Twelve organizations have issued a joint public comment on the Consumer Financial Protection Bureau proposed rule entitled “Qualified Mortgage Definition Under the Truth in Lending Act (Regulation Z): General QM Loan Definition”. The comment was written on Sept. 8, 2020, and posted on Sept. 9, 2020:

The comment was co-signed by the American Bankers Association, Bank Policy Institute, Consumer Bankers Association, Center for Responsible Lending, Housing Policy Council, Leadership Conference on Civil Rights and Human Rights, National Association of Hispanic Real Estate Professionals, National Association of Real Estate Brokers, National Community Reinvestment Coalition, National Fair Housing Alliance, National Housing Conference and U.S. Mortgage Insurers.

“Whether it’s three months from now, or six months from now, or a year from now, having millions of people be evicted because they can’t pay a year’s worth of rent is not a solution.” – David Dworkin

“The money homeowners save on their mortgage through refinancing is going to go somewhere. Plus, they’re strengthening their bottom line, which is important when you’re in a recession.” – David M. Dworkin

National Housing Conference President and CEO David Dworkin said the order “kicks the crisis down the road to January when the weather will be colder, and more people will be in even greater crisis.”

For property owners, [the CDC’s eviction order] is a crushing unfunded mandate that will bankrupt many small businesses.” – David M. Dworkin

“We don’t want the small business people who own most of the apartment buildings and single-family rentals in the country to go out of business.” – David Dworkin

As many tenant advocates have warned, the administration’s plan is a temporary solution to the country’s bubbling housing challenges, one that won’t necessarily save every family in distress, even during the short term. “It is a stopgap measure. It will not be totally effective. People will definitely fall through the cracks.” – David Dworkin

“There is broad agreement across the housing industry that the only real solution to this crisis is federal rental assistance. For property owners, it is a crushing unfunded mandate that will bankrupt many small businesses. For 43 million renter households, it creates a complicated and opaque maze that those most in need cannot possibly navigate. Congress and the White House must reconvene negotiations on a comprehensive solution immediately. Treasury secretary Steven Mnuchin has said, ‘Our first choice is to have bipartisan legislation that allocates specific rental assistance to people hardest hit.’ If there’s that much agreement, then there is no reason to delay any further.” – David M. Dworkin

“[The order] kicks the crisis down the road to January, when the weather will be colder and more people will be in even greater crisis.” -David M. Dworkin

“We could still have millions of evictions in January, in the middle of winter, and all we will have accomplished is evicting people in colder weather.” – David M. Dworkin