Comment on CFPB-2013-0010-0001

I am writing on behalf of SchoolsFirst Federal Credit Union (SchoolsFirst FCU), which serves school employees in Southern California. We have more than 500,000 Members and over $9 billion in assets. SchoolsFirst FCU appreciates the opportunity to comment on the proposed amendments to the 2013 Mortgage Rules under the Real Estate Settlement Procedures Act (Regulation X) and the Truth in Lending Act (Regulation Z). Specifically, we will focus our comments on the proposed revisions to 12 CFR §1026.43 Minimum Standards for Transactions Secured by a Dwelling, commonly referred to as the Qualified Mortgage rule. Generally, SchoolsFirst FCU supports the proposed clarifications and revisions, and we applaud the Bureau for addressing the challenges and risks that would be created by certain ambiguous and burdensome requirements contained in Appendix Q - Standards for Determining Monthly Debt and Income. However, in the Consumer Eligibility section, there are two areas of concern with respect to proposed changes for determining income for the purposes of the debt to income ratio calculation. Consumer Eligibility – Section 1A. Stability of Income The proposal revises the requirement that in order to determine the probability of continued employment, the creditor is required to obtain the employer’s confirmation of continued employment. Rather, the proposal would “require only that the creditor examine a confirmation of current, ongoing employment.” The addition of a proposed note clarifies that “creditors may assume that employment is ongoing if a consumer’s employer verifies current employment and does not indicate that employment has been, or is set to be terminated.” The proposed note would further state that “creditors should not rely upon a verification of current employment that includes an affirmative statement that the employment is likely to cease, such as a statement that indicates the employee has given or been given notice of employment suspension or termi