On April 19, the CFPB released proposed rule amendments to the ability to repay/qualified mortgage (QM) rules.  The proposals address: (i) clearer rules for determining DTI; (ii) confirmation regarding loans meeting eligibility requirements; (iii) that certain GSE or agency requirements do not impact the determination of QM status; (iv) that there is no field preemption under Regulation X; and (v) which mortgage loans to consider in determining whether a servicer qualifies as a ‘small servicer.’  Comments on the proposed amendments must be received within 30 days of publication in the Federal Register.  CFPB Release.  Proposed Rules.