NHC submitted comments to regulators on the Qualified Residential Mortgage (QRM) rule calling for the elimination of the 20% downpayment requirement, focusing instead on defining the QRM pool primarily as safe and sound mortgage products that include responsibly structured low-downpayment options without creating an unintended government underwriting standard. In summary, the recommendations are:
1. Remove downpayment and LTV requirements. (The 10% downpayment requirement offered in the proposed rule would actually be worse.)
2. Consider removing or relaxing debt-to-income ratio requirements.
3. Exempt downpayment assistance and shared equity assistance programs created by government entities and designated, legitimate nonprofits, whether structured as loans, grants, or lower sales prices with resale restrictions.
4. Consider delaying implementation until other aspects of the mortgage finance system are resolved, or making provisions now to require that regulators revisit the rule when other major changes to mortgage finance occur.
Regulators are accepting comments through August 1, so there is still time to submit your own. See NHC’s comment letter for a full discussion of the QRM issue.