Riding the Horse Backwards


Many regulators have signed on to the Qualified Residential Mortgage and risk retention provisions, since their view essentially is that "credit risk retention" should be required because they believe it encourages prudent underwriting and securitization.

Recently, Barney Frank (D-MA) spoke about a "revolt" against the risk retention regulations embodied in the Qualified Residential Mortgage provisions of the Dodd-Frank Act.

We've heard about the risk retention requirement by its euphemistic cognate, rather barbarically described as to "keep skin in the game." For the time being, though, maybe we should reflect a bit on Congressman Frank's worries.

This article offers commentary on the Qualified Residential Mortgage.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Jonathan Foxx, Lenders Compliance Group | Attorney Advertising

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