Results of the Shelterforce poll of October 12, 2011
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You said:
“20 percent is far more than necessary to protect banks against defaults and would price homeownership out of reach for middle- and lower-income homebuyers.”
“If we have QRM with a much larger downpayment requirement, it could force banks to make loans with retained risk at whatever down payment level they would do otherwise. If we reduce the downpayment level to 3 or 5%, if will ensure that banks invecentives to lend to at various levels is not distorted. But 20% will simply mean that very few loans are offered at lower down-payments at any kind of reasonable price.”
“The proposed 20 percent QRM rule will hamper the ability of many Americans to become homeowners, especially people of color living in LMI communities. QRM will also impede banks’ ability to fulfill their CRA lending and investment obligations in LMI communities and have a significant impact on revitalization efforts. It will also further the gentrification of vulnerable communities as higher income suburbanites and new urbanist infiltrate urban communities. QRM will pose a discriminatory effect on people of color who have been the most negatively impacted by the mortgage meltdown and have the least opportunity to recover from the recession and weak credit. It’s simple, QRM is bad policy and undermines 30 years of progress to advance the ability of LMI borrowers to build and preserve assets and wealth.”
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