The National Foreclosure Prevention and Neighborhood Stabilization Task Force, which NHC chairs with Enterprise Community Partners and NeighborWorks America, submitted comments on QRM today, recommending regulators to remain cautious of harming struggling neighborhoods by requiring an overly-restrictive downpayment of 20%. This task force is a cross-industry group of local, state and national organizations working to address the impacts of the foreclosure crisis on communities. See the National Foreclosure Prevention and Neighborhood Stabilization Task Force comment letter for more information.
NHC also submitted comments in partnership with NCB Capital Impact specifically on the issue of affordable homeownership programs funded by local governments and non-profit organizations. In brief, the proposed rules exclude from the definition of QRM many home loans for borrowers that receive assistance through a government-funded or nonprofit affordable homeownership program. These are some of the safest loans for low- and moderate-income families and thus deserve to be included in the definition of QRM. See the joint letter submitted by NCB Capital Impact, NHC and endorsed by 55 organizations from around the country here.
NHC already submitted detailed comments earlier this week. Regulators are accepting comments through August 1, so there is still time to submit your own. See NHC’s comment letter and blog post for a full discussion of the QRM issue.