At issue: the new QM standards were drafted when the CFPB was under the leadership of Republican Kathleen Kraninger, who was appointed during the Trump administration.
The RFI appears to be in response to long-standing complaints about how the GSEs deal with properties that earn an income by providing transient housing...
Mark Calabria: "Just like other large financial institutions, these plans will provide Fannie Mae, Freddie Mac and FHFA with a roadmap for preserving business continuity should they fail again."
Jeffrey Naimon, a partner at Buckley, warned that CFPB enforcement lawyers are pressing hard on discovery issues — requiring investigational targets to provide more information faster.
While the Treasury and FHFA said the 7% cap was “aligned with the current levels” of acquisitions by the GSEs, some analysts believe the loans have accounted for somewhat more than 7% of purchases by Fannie and Freddie each year since 2013.
The upfront MIP is 175 bps of the base loan amount on a 30-year fixed-rate FHA single-family loan. Most FHA borrowers pay an annual MIP of 85 bps for the full life of the loan.