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Better Markets Issues Comment Letter on the CFPB's Seasoned QM Loan Proposal

On Oct. 1, 2020, Better Markets filed a comment letter on a proposal from the CFPB to amend its “Qualified Mortgage” rules to allow any mortgage to be considered a qualified mortgage so long as it had a limited number of delinquencies in its first three years. This proposal threatens the stability of the housing market, unlawfully exceeds the authority of the CFPB, and offers no concrete benefit to consumers.