On June 5, 2012, the Consumer Financial Protection Bureau (CFPB) published in the Federal Register (77 FR 33120) a “Notice of reopening of comment period and request for comment” (Notice) regarding the proposed rule the Federal Reserve Board (FRB) published in the May 11, 2011 Federal Register (76 FR 27390) addressing ability-to-repay requirements applicable to consumer credit transactions secured by a dwelling and defining a “qualified mortgage.” Although the proposed rule’s original comment period ended on July 22, 2011, the CFPB is reopening the comment period until July 9, 2012, for comment on new data and information submitted during or obtained after the close of the original comment period that is discussed in the Notice. The Notice is focused on this new data and information and does not reopen comment on other aspects of the proposed rule. The Notice may be found in the June 5, 2012, Federal Register at:http://www.gpo.gov/fdsys/pkg/FR-2012-06-05/pdf/2012-13608.pdf. Those clients wishing to comment must submit comments in the following manner: 1. Comments must be received on or before July 9, 2012. 2. Comments must be identified by Docket No. CFPB-2012-0022 or RIN 3170-AA17. 3. Comments must be submitted by one or more of the following methods: • Electronic: http://www.regulations.gov. Follow the instructions for submitting comments. • Mail or Hand Delivery/Courier in Lieu of Mail: Monica Jackson, Office of the Executive Secretary, Bureau of Consumer Financial Protection, 1700 G Street NW., Washington, DC 20552. 4. All submissions must include the agency name and above Docket Number or Regulatory Information Number (RIN).

Complete Memorandum