SIFMA provides comments to the Bureau of Consumer Financial Protection (CFPB) on Qualified Mortgage (QM); Regulation Z; and Truth in Lending; Docket No. R-1417; RIN No. 7100-AD75. SIFMA address three points related to qualified mortgage regulation: (1) the parameters of the qualified mortgage definition must be scaled broadly, as opposed to narrowly, as QM loans will be predominant source of widely available mortgage credit; (2) due to the risk of liability inherent in non-QM lending, the parameters of the definition must provide clear, bright lines, and a safe harbor for compliance; and (3) the need for further, more detailed discussion of these issues with secondary market participants.