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ICBA encouraged the CFPB to expand on its proposal to create a new category of "seasoned" qualified mortgages. The plan would allow non-QM mortgages to “season” into QMs based on strong performance over 36 months to expand access to credit for creditworthy consumers.
ICBA asked the CFPB to apply the rule retroactively for eligible loans made before the effective date of the final rule.
It also encouraged the bureau to modify the exemption for small creditors by shortening their seasoning period from 36 to 24 months and raising the small creditor threshold from $2 billion to $10 billion in assets, which would benefit community banks that hold loans in portfolio.