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The MBA recently wrote a letter to federal housing regulators opining that mortgages with adjustable rates should qualify for an exemption from the risk-retention rules as long as they have an initial fixed payment period of at least three years. Feel free to check out some relevant links:
1. http://www.federalreserve.gov/newsevents/press/bcreg/20101117a.htm
2. http://www.federalreserve.gov/newsevents/press/bcreg/20101117b.htm
3. http://blogs.wsj.com/developments/2010/11/10/mortgage-lenders-push-for-exemption-from-dodd-frank/
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