While the Department of Housing and Urban Developments proposed definition of a qualified mortgage is superior to the treatment FHA-insured mortgage loans would receive under the Consumer Financial Protection Bureaus QM rule, it would add significant regulatory burden and costs and increase litigation risks, warned mortgage lenders. HUDs proposed distinction between safe harbor and rebuttable presumption loans is unnecessary for FHA loans because they already meet QM requirements, according to industry trade groups. Rebuttable presumption would only impose more costs and reduce credit availability for borrowers who need FHA credit the most and likely create more confusion, lenders said. The inclusion of the FHA annual mortgage insurance premium (MIP) in the annual percentage calculation under the CFPB rule would cause...