Balancing Risk and Access: Underwriting Standards for Qualified Residential Mortgages

As policymakers develop underwriting guidelines for qualified residential mortgages (QRM) — which are exempt from risk retention requirements for privately securitized mortgages under the Dodd-Frank Wall Street Reform and Consumer Protection Act — both consumer and industry groups have raised concerns about the disproportionate impact that restrictive QRM guidelines may have on low-income, low-wealth, minority, and other households traditionally underserved by the mainstream mortgage market. In this study, we examine the way different QRM guidelines may affect access to mortgage credit and loan performance, with a special focus on historically underserved households. More narrowly, we estimate the additional impacts on defaults and access resulting from setting QRM underwriting guidelines over and above the proposed product restrictions for qualified mortgages (QM), which exclude loans with features associated with higher default rates. We find that the added benefits of reduced foreclosures resulting from restrictions beyond the QM product requirements do not necessarily outweigh the costs of reducing borrowers’ access to QRM mortgages. In particular, LTV requirements of 80 or 90 percent produce a smaller benefit when the resulting reductions in defaults are weighed against the number of borrowers excluded from the market. The results for debt-to-income (DTI) and borrower credit scores (FICO) similarly show that the most restrictive thresholds are less effective because they exclude a larger share of borrowers in relation to percent of defaults they prevent. In addition, we find that more stringent LTV, DTI, and FICO requirements could disproportionately deny low-income borrowers and borrowers of color access to QRM mortgages.