NAR submitted a comment letter to the Consumer Financial Protection Bureau (CFPB) requesting an extended time period of at least one year to sunset the QM patch and to implement the proposed replacement. 

NAR reasons that for the near future, lenders and the market must focus on the pandemic response. Furthermore, the GSE capital rule could raise costs for borrowers, which could hurt access to credit or destabilize the market and therefore deserves more study. The recent ruling by the supreme court found that the CFPB's leadership is removable for cause by the President making the future of this policy unclear, which could cause a costly burden for the market as participants would be forced to prepare for a rule that might be changed with a new administration. Finally, based on the implementation of the original QM rule, it took lenders roughly a year to comply.