Staff and members of the Mortgage Bankers Association met with the CFPB in recent weeks to discuss how to determine the “interest rate without any discount” that is used to calculate the starting point at which bona fide discount points can be used to reduce the rate and are eligible for exclusion from the qualified mortgage’s points-and-fees cap. Specifically, MBA asked if the interest rate to be used is the rate unique to each consumer or is simply a rate from a standard rate sheet. The trade group also wanted to know what the...