The new version incorporates lessons learned from the financial crisis of 2008 along with contemporary concerns about mortgage originations and servicing.
“While we’re trying to lend fairly in an unfair world, the regulatory and enforcement apparatus have created this environment that we’re in and they will be looking to enforce based upon those rules,” said industry consultant Maurice Jourdain-Earl.
Adam Levitin, a professor at Georgetown University Law Center, is critical of efforts to align the QRM rule with the QM. “Skin in the game is meant to be a systemic stability regulation, but it has instead been pegged to a consumer protection regulation,” he said.