CBAI Urges Expanded QM Exemptions for Community Banks

February 22, 2013

The Community Bankers Association of Illinois (CBAI) urged the Consumer Financial Protection Bureau (CFPB) to expand the Qualified Mortgage (QM) exemptions by creating a new category of QMs for community banks which would benefit from a conclusive safe harbor presumption with the ability-to-repay rules. CBAI supports the exemption thresholds being set higher than the proposed levels (to $5 billion in assets and 3,500 transactions) so that some community banks do not confront the loss of the safe harbor. CBAI also supports giving community banks a reasonable amount of time to either fall back below the thresholds or be given a reasonable period of time to prepare for the change. In addition, the definitions of “rural” and “underserved” should be expanded to level the competitive playing field for community banks and to encourage them to better serve low-to-moderate income borrowers and communities. Read Comment Letter