It appears that certain regulatory agencies want the 'qualified residential mortgage' test to be written in such a way that a QRM loan will be one with a downpayment of at least 10%. (If that happens you can bet that Wells Fargo will place a huge order for champagne.) Where the mortgage insurance piece plays out is unclear. Right now, the situation is fluid and won't be decided until the end of February. Among the regulators, the Comptroller of the Currency favors a low downpayment QRM definition. Have any insight on what's going on? Drop me a line at:
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