National trade groups representing mortgage lenders of all sizes recently advised the CFPB to broaden the scope of its pending assessment of its ability-to-repay/qualified mortgage rule. The Mortgage Bankers Association, for instance, provided the bureau with multiple concerns it believes must be addressed, such as making sure the rule better serves millennials and immigrants who are entering the housing market. Other concerns include “the limitations of the 43 percent debt-to-income requirement that does not include compensating factors,” and whether the underwriting guides of the government-sponsored enterprises and government programs could serve as alternatives to Appendix Q. The Consumer Mortgage Coalition recommended that the agency begin its review process by analyzing the products and product structures that contributed to the financial ...