One of the biggest issues mortgage lenders will face is implementing changes to the general qualified-mortgage rule, which has a mandatory compliance date of July 2021.

The Mortgage Bankers Association has drafted a model bill for state regulators to provide regulatory flexibility allowing mortgage loan originators to work from home, with prescribed regulator standards for consumer and data protection.

Citing existing mortgage regulations at the federal level, the Urban Institute said it might be most appropriate for the FHFA or the Federal Reserve to regulate nonbank mortgage servicers.