The ability-to-repay rule promulgated by the Consumer Financial Protection Bureau is perhaps the single most important mortgage-related regulation the CFPB will produce under the Dodd-Frank Act, and mortgage lenders will need a vigorous and comprehensive strategy if they are going to make qualified mortgages profitably while maintaining the desired level of legal protection. But before lenders get to the compliance pieces of the QM puzzle, they’ve got to figure out “how to get to QM” and what types of loans they want to make. “We’re assuming...