The Evidence Supports the CFPB’s New Seasoning Pathway to Safe Harbor

Urban Institute, Jan. 29, 2021–Karan Kaul, Laurie Goodman, Jun Zhu
This brief analyzes historical loan performance to study the CFPB’s newly issued Seasoning QM Rule, which would provide a 3-year pathway to safe harbor for loans that are rebuttable presumption or nonqualified mortgages at the time of origination. This analysis shows that loan performance during the first three years is a better predictor of subsequent loan performance than the rate spread.
https://www.urban.org/research/publication/evidence-supports-cfpbs-new-seasoning-pathway-safe-harbor