131030_qrm_woodstock.pdfThis comment letter to federal regulators supports re-proposed interagency rules implementing the credit risk retention requirements of the Dodd-Frank Wall Street Reform and Consumer Protection Act. It urges regulators to support the qualified residential mortgage (QRM) rule’s updated structure, which will protect both consumers and investors by promoting high-quality underwriting while not overly limiting credit in an already-tight credit market. The rule’s proposed alternative definition imposes unnecessarily strict underwriting requirements for the QRM that would risk overly restricting credit availability, particularly for low-wealth homebuyers and homebuyers of color.
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