SIFMA provides comments to the Board of Governors of the Federal Reserve System (Federal Reserve) on proposals relating to amendments to Regulation Z (Truth in Lending) that would implement changes to the Truth in Lending Act (TILA) made by the Dodd-Frank Wall Street Reform and Consumer Protection Act (the Dodd-Frank Act).  SIFMA notes the importance of this rulemaking, in particular the incorporated definition of “qualified mortgage” (QM).  SIFMA offers its recommendations and observations on the proposal, focusing on the application of the QM to secondary markets.