Transcript Qualified Mortgages

K&L Gates Webinar Series
Ability-to-Repay, QM, and Points & Fees
What You Really Need to Know
N. Akilah Green
K&L Gates LLP
[email protected]
202-661-3752
Jonathan Jaffe, Esq.
K&L Gates LLP
[email protected]
415-249-1023
Phillip L. Schulman, Esq.
K&L Gates LLP
[email protected]
202-778-9027
DC 9672282 v2
Copyright © 2013 by K&L Gates LLP. All rights reserved.
Kris D. Kully, Esq.
K&L Gates LLP
[email protected]
202-778-9301
David T. Tallman, Esq.
K&L Gates LLP
[email protected]
202-778-9046
January 30, 2013
I.
INTRODUCTION
A. Background
1. Laissez-Faire Attitude
2. Anything Goes – Up & Went
3. Congress Steps In = Dodd-Frank Act

attempts to control risk

clean up Wall Street

protect consumers
2
B.
CFPB Mandated to Address Mortgage Processes
1.
Every aspect of origination and servicing being
examined
2.
Objectives
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3.
timely, understandable information
eliminate deceptive practices
enforce consumer laws
Regulations flying off the presses
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combined TILA-RESPA forms
LO compensation
servicing standards
appraisal requirements for high-priced
mortgage loans
final HOEPA rules
expanded escrow periods
3
C. Today We Address ATR and QM
1.
Congress and CFPB concerned that too many consumers
placed in loans they could not repay
2.
View that lenders approved borrowers without considering
ATR
failure to verify consumer income and debts
loans based on teaser rates

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3.
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
Section 1411 of the Dodd-Frank Act
requires creditors to make reasonable good
faith determination of consumer’s ability to repay

based upon verified documented information
4.
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
January 10, 2013
CFPB issues final ATR Rule
effective January 10, 2014
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D. Covered Transactions
1.
Covered Transactions are consumer credit transactions
secured by a dwelling
 first lien
 subordinate lien
2.
Higher-Priced Covered Transactions
 1.5% or more above APOR for first lien
loans
 3.5% or more above APOR for
subordinate liens
3.
Excluded Transactions
 HELOC
 time share plans
 reverse mortgages
 construction loans
 temporary bridge loans
 business purpose loans
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II.
SUMMARY OF ABILITY TO REPAY RULE
A.
General Requirements
1. Creditor must make a reasonable and good
faith determination at or before
consummation that the consumer will have a
reasonable ability to repay the loan
according to its terms
2. Creditor must verify consumers’ ATR using
reasonably reliable third-party records
3. Bureau does not dictate a particular
underwriting model
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B.
Basis for Determination
At a minimum creditors must consider 8
underwriting factors:
1.
Current or reasonably expected income or assets
2.
Current employment status
3.
Monthly payment on covered transaction
4.
Monthly payment on simultaneous loan
5.
Monthly payment for mortgage-related obligations
6.
Current debt obligations, alimony, child support
7.
Monthly debt-to-income ratio or residual income
8.
Credit history
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C. Standard vs. Non-standard Loans
1.
Standard loan means covered transaction



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


with regular periodic payments
in which principal balance does not increase
no deferral of principal (no I/O)
no balloon payments
prescribed points and fees
term does not exceed 40 years
fixed interest rate for first 5 years
proceeds used to pay off non-standard loan or for closing
and settlement charges
2.
Non-standard loan means covered transaction that is

ARM loan with introductory fixed rate for a year
or more
interest only
negative amortization
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
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III. QUALIFIED MORTGAGE
A.
Presumption of ATR
1. Conclusive (safe harbor) vs. Rebuttable
Presumption

FRB 2011 proposed rule contemplated
either/or

CFPB Rule provides for both

Safe harbor for non-higher priced covered
transactions (prime loans)

Rebuttable presumption for higher priced
covered transactions
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B.
QM Defined
1.
Regular substantially equal periodic payments
except for prescribed adjustable-rate increases that
do not include
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

negative amortization
interest only
balloon payment
2.
Term does not exceed 30 years
3.
Total points and fees do not exceed 3% (for loans
of $100,000 or more)
4.
Monthly payment calculated based on highest
payment that applies in first 5 years
5.
Consider current or reasonably expected income,
debt obligations, alimony, child support
6.
Total debt-to-income ratio does not exceed 43%
10
C.
Temporary QMs
1.
Loans that have regular substantially equal periodic
payments, term does not exceed 30 years, points and
fees do not exceed 3% AND
2.
Loan is eligible to be

guaranteed/purchased Fannie Mae (while under
conservatorship)

guaranteed/purchased Freddie Mac (while under
conservatorship)

insured by FHA or RHS

guaranteed by VA or Dept. of Agriculture
For 7 years or until agencies publish their own QM rules
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D.
Additional Alternatives to Assuring ATR
1.
Rural balloon payment QMs
2.
Refinancing a non-standard loan into a standard
loan
3.
Concurrent proposal under consideration to add
additional exemptions

credit extended to Housing Finance Agency

credit extended to certain non-profit creditors

credit extended under the EESA

credit extended by certain small creditors

credit extended by small creditors making balloon
loans
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Ability to Repay:
Why Care?
13
Ability to Repay
General Rule
 For loans subject to the ATR, creditors must make “a
reasonable and good faith determination at or before
consummation that the consumer will have a reasonable
ability to repay the loan according to its terms.”
 Can meet that requirement in one of four ways:
 ATR
 QM
 Refinancing a non-standard mortgage into a standard
mortgage
 By making a qualifying balloon mortgage in a rural or
underserved area, if the creditor is small and services
primarily rural or underserved areas
14
Ability to Repay, cont.
Why Care About ATR?
 Common wisdom is that everyone will follow the QM
 Remains to be seen whether the MBS market will
tolerate the risk
 Portfolio lenders might accept the risk to serve
customers
 If fail to meet QM test, might be able to prove met
ATR test
15
Ability to Repay, cont.
Covered Loans to Which ATR (and Therefore the
QM) Applies
 The ATR – and the QM – applies to all consumerpurpose, closed-end loans secured by a dwelling
 First and junior lien, home-purchase, refinance and
home equity loans
 Do not apply to:
 Business-purpose loans, even if secured by a dwelling
(TILA applies only to consumer loans)
 Open-end credit, e.g., HELOCS (no structuring as
open-end to evade ATR) – CFPB intends to monitor
the HELOC exemption
16
Ability to Repay, cont.
Covered Loans
 ATR and QM do not apply to:
 Timeshare loans
 Reverse mortgages
 Bridge or temporary loans with terms of 12 months or
less
 Loans to finance the initial construction of a dwelling or to
finance the purchase of a new dwelling where the consumer
plans to sell a current dwelling within 12 months
 The construction phase of a construction-to-perm loan,
provided the construction phase is 12 months or less
 Loan mods (unless the mod is a refinancing)
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Ability to Repay, cont.
Two Things a Creditor Must Do
 Follow underwriting requirements and verify what
they rely on in making credit decisions
 No limits on points and fees or most product features
 Lots of underwriting and verification requirements, but
unlike QM, there isn’t much detail
 E.g., doesn’t specify income needed to support debt or
how credit history should be weighed against other
factors
 Creditors may develop their own standards and make
changes over time in response to empirical information
and changing economic and other conditions
18
Ability to Repay, cont.
Two Things a Creditor Must Do
 So have some flexibility, but with flexibility comes
potential regulatory risk
 Many of the requirements impose “reasonableness” or
“good faith“ standard on creditor
 The ATR notes that a creditor may refer to GSE
guidance
19
Ability to Repay, cont.
Eight Underwriting Factors
 Creditor must consider eight underwriting
factors
1. Current or reasonably expected income or assets (other
than the value of the collateral)
 May consider only assets, and only the income and
assets needed to determine that the consumer can
repay the loan
2. The consumer’s current employment status, to the extent
the creditor relies on employment income
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Ability to Repay, cont.
Eight Underwriting Factors
3. The monthly loan payment on the covered
transaction


For fixed and ARMs, the payments must be monthly,
substantially equal and sufficient to fully amortize the
loan over its term
For ARMs, the payments must be based on the higher
of the fully indexed rate or introductory rate
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Ability to Repay, cont.
Eight Underwriting Factors
4. The monthly payment on any “simultaneous loan” that the
creditor “knows or has reason to know” will be made


E.g., Piggyback loans (even HELOCs and loans closed
by another creditor) secured by the same property
Not required to investigate, but likely to turn up in
underwriting or closing
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Ability to Repay, cont.
Eight Underwriting Factors
5. Monthly payment for “mortgage-related
obligations,” i.e., insurance premiums if
insurance is required by the creditor, obligations
to community governance associations (e.g.,
HOA assessments), property taxes, ground rent,
and lease payments
6. Current debt obligations, alimony and child
support
 Some flexibility based on facts and
circumstances, e.g., likelihood that obligation
will be paid off shortly after consummation
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Ability to Repay, cont.
Eight Underwriting Factors
7. Monthly DTI ratio or residual income
 Again, purports to offer a great deal of
flexibility in determining what is debt and
income
 For example, creditors may consider
compensating factors in addition to the DTI or
residual income in assessing a consumer’s
repayment ability (reasonable and good faith
standard)
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Ability to Repay, cont.
Eight Underwriting Factors
8. Credit history, but a credit report not required
 Again, purports to offer flexibility by permitting
creditor to “give various aspects of a
consumer’s credit history as much or as little
weight as is appropriate to reach a
reasonable, good faith determination of ability
to repay,” but subject to reasonable, good
faith consideration
25
Ability to Repay, cont.
Verification

Creditors must make a reasonable and good faith
determination, based on “verified and documented
information,” that a consumer has a reasonable ability to
repay the covered transaction


Differs from HOEPA’s existing requirement to verify
consumer’s income or assets
For most part, creditors are to use third-party records

A document or other record prepared or reviewed by an
appropriate person other than the consumer, the creditor,
or the mortgage broker or an agent of the creditor or
mortgage broker
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Ability to Repay, cont.
Verification

Third-party records may come from the consumer, provided
they are reasonably reliable and specific to the individual
consumer, e.g., payroll statements from the consumer

Examples

Credit history, but a credit report not required

Again, purports to offer flexibility by permitting creditor to
“give various aspects of a consumer’s credit history as much
or as little weight as is appropriate to reach a reasonable,
good faith determination of ability to repay,” but subject to
reasonable, good faith consideration
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Ability to Repay, cont.
Verification

Examples

Credit report, including the information in it, the existence
and amount of a debt – but only if noted on the report, and
can’t rely if knows or has reason to know it’s inaccurate

Copy of a tax return filed with the taxing authority, such as
the IRS

Record from a government agency of the amount of any
benefit payments or awards, e.g., “proof of income letter”
issued by the Social Security Administration
28
Ability to Repay, cont.
Verification

Examples


Homeowners association billing statements provided by
the seller
What isn’t a third-party record?

Using average incomes in the consumer’s geographic
location or average wages paid by the consumer’s
employer
29
Qualified Mortgages:
What are they good for?
30
Qualified Mortgages
Dodd-Frank Act: A creditor/assignee “may presume” that a
loan has met the ability-to-repay requirements if the loan is
a Qualified Mortgage.
 Dodd-Frank Act established core criteria:
 Regular periodic payments – no negative
amortization, balloon payments only in limited
circumstances
 Borrower’s income and financial resources must
be verified and documented
 Underwriting must be based on a fully amortizing
payment schedule and take into account taxes,
insurance, and assessments
31
Qualified Mortgages
 Dodd-Frank Act established core criteria (cont.):
 Total points and fees (as redefined) do not exceed 3%
of the total loan amount
 Loan term does not exceed 30 years (with limited
exception)
 Board/CFPB may establish debt-to-income ratios or
alternative measures of ability to pay regular expenses
after payment of total monthly debt
32
Qualified Mortgages
Safe Harbor – QMs that are not higher priced are
deemed to comply with the ability-to-repay requirements
Rebuttable Presumption – QMs that are higher priced
are presumed to comply with ability-to-repay
requirements
 First Liens: APR 1.5 over APOR
 Second Liens: APR 3.5 over APOR
 To rebut presumption: Borrower must prove that creditor
did not make reasonable, good faith determination of
repayment ability, because consumer’s income, debt,
alimony, child support, and monthly payments would leave
consumer with insufficient residual income or assets to
meet living expenses of which the creditor was aware
33
Qualified Mortgages
Final Rule: Regulation Z Section 1026.43(e)(2)
defines Qualified Mortgage:
 Provides for safe harbor, but rebuttable
presumption for higher APR loans
 Adds a maximum DTI ratio
 Interprets “points and fees” broadly
 Temporarily carves out Fannie/Freddie/FHA
eligible loans
 Proposes other exemptions and QM definitions
34
Qualified Mortgages
A covered transaction with following characteristics:
 Regular periodic payments (i.e., substantially equal – no
neg am, deferral of principal repayments, or balloons, with
limited exceptions)
 Loan term not over 30 years
 Total points and fees do not exceed 3% (different
thresholds for loans under $100,000)
 Must consider monthly payments for property taxes;
premiums for insurance required by the creditor; fees and
special assessments
 Must consider maximum rate during the first 5 years after
the first regular periodic payment will be due
 Must consider periodic payments of principal and interest
that will repay the loan amount over the loan term (or the
outstanding principal balance over the remaining term
once the rate adjusts to its maximum)
35
Qualified Mortgages
 Must consider and verify, in accordance with
Appendix Q:
 Current or reasonably expected income or assets
 Current debt obligations, alimony, child support
 Verification = reasonably reliable third-party
records (rule provides examples)
 Monthly DTI at consummation does not exceed
43% (using App. Q)
 Must include monthly mortgage-related obligations
and simultaneous loans about which creditor
knows/has reason to know
36
Qualified Mortgages
Total Points and Fees – 3%
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For loans $60K to less than $100K: $3000
For loans $20K to less than $60K: 5%
For loans $12.5K to less than $20K: $1000
For loans less than $12.5K: 8%
Amounts will be adjusted annually for inflation
Definition of Points and Fees
 Same definition for QM and HOEPA Loans (different thresholds)
 Revised/expanded definition (generally includes direct and indirect loan
originator compensation, LLPAs, affiliate fees)
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Same-Creditor Refinancing of Non-Standard
Loans
 “Non-Standard” – ARMs with introductory fixed rate period, IOs, Neg
Ams
 “Standard” – Regular periodic amortizing payments, with no balloon,
3% points and fees, terms not exceeding 40 years, fixed rate for first 5
years, no cash out
 Exempt from Ability to Repay if:
 Same creditor (creditor for the new mortgage is the current holder or
servicer acting on behalf of current holder)
 New monthly payments materially lower
 Creditor receives application no later than two months after the nonstandard mortgage has recast
 Consumer has no more than one 30-day late during preceding 12
months; no 30-day lates during the preceding 6 months
 Creditor must consider whether standard mortgage likely to prevent a
default on non-standard mortgage once the loan is recast
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Points and Fees
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Points and Fees
A.
What is included in “points and fees”?
The following, if “known at or before consummation”:
1.
Items in TILA finance charge, other than interest
2.
Loan originator compensation paid by the consumer or
creditor, whenever payable, if attributable to the transaction
and known at the time the interest rate is set
3.
Real estate related fees (1026.4(c)(7)), other than bona fide
and reasonable enumerated charges not paid to the creditor,
originator, or an affiliate (see exclusions)
4.
Credit insurance, debt cancellation premiums, etc. payable at
or before consummation
5.
Prepayment penalties:

Maximum amount under the new mortgage

Total penalty under existing mortgage if the new
mortgage is a refinance of a loan with the current
holder or servicer, or an affiliate of either
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B.
What counts as “loan originator compensation”?
1.
Compensation payable to a loan originator by creditor or
consumer for the specific transaction (whenever payable), if
known at time rate is set:

Includes broker and individual LO compensation

Includes bonus, commission, yield spread premium,
award of merchandise, services, trips, or similar prizes, or
hourly pay for the actual number of hours worked on a
particular transaction
2.
Excludes compensation not attributable to particular
transaction at origination, such as base salary or
compensation based on the performance or overall quality of
originated loans
3.
Issues include need to track individual LO compensation,
double-counting (“additive” effect)

Bureau recognizes issues, but finalized rule “without
qualifying the statutory result.” Concurrent proposed rule
seeks comments on potential resolutions
41
C.
What is excluded from “points and fees”?
1.
Interest and time-price differential
2.
Gov’t mortgage insurance/guaranty fees; PMI payable after
consummation; PMI payable at or before consummation not in
excess of FHA standards if refundable on pro rata basis
3.
Bona fide and reasonable real estate related fees not paid to the
creditor, originator, or an affiliate for title, document preparation,
notary, credit report, appraisal, inspection, pest removal, or flood
hazard determination services
4.
Bona fide third-party charges not retained by the creditor,
originator, or an affiliate (except otherwise included
mortgage/credit insurance premiums and real estate related fees)

5.
Exclusion does not cover LLPAs
Bona fide discount points, limited to:

2 points if undiscounted rate does not exceed the APOR by
more than 1 point

1 point if undiscounted rate does not exceed APOR by more
than 2 points

Use average Title I rate if secured by personal property
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D.
What is a “bona fide discount point”?
1.
Knowingly paid by the borrower for the purpose of
reducing the interest rate
2.
Actually results in a bona fide reduction of the
interest rate
3.
Reduction must be consistent with established
industry practices for determining the amount of rate
reduction
4.
Final rule does not require a relationship between the
amount of interest rate reduction purchased by a
discount point and the value of the transaction in the
secondary market
5.
Use of APOR thresholds without adjustment may
cause problems for jumbo loans, second homes, etc.
43
E.
Timing Considerations
1.
Private mortgage insurance and credit
insurance premiums etc. are included if they are
“payable at or before closing”
2.
All other charges are included if they are “known
at or before consummation”
3.
Potential fees for servicing-related actions,
including modification fees, are not included as
“points and fees”
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Other Types of Qualified Mortgages
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Alternative/Temporary Qualified Mortgage
 Fannie Mae or Freddie Mac: Loans eligible to be
purchased or guaranteed by GSEs while under
conservatorship or receivership (or limited life
successor entity)
 Desktop Underwriter “Approve/Eligible”
 Loan Prospector “Accept and Eligible to Purchase”
 Conformity with Single-Family Selling Guides
 FHA, VA, USDA, RHS: Loans eligible to be
insured or guaranteed by agencies, until
agencies issue their own QM rules
46
Alternative/Temporary Qualified Mortgage
 Fannie Mae/Freddie Mac/FHA/VA/USDA/RHS
QMs:
 Also must have regular, substantially equal
periodic payments (allowing for payment changes
on ARMs or step-rates)
 No negative amortization
 No deferment of repayment of principal (limited exception)
 No balloon (limited exception)
 Loan term does not exceed 30 years
 Total points and fees do not exceed 3% (or
different threshold for smaller loans)
 Sunset: January 10, 2021 (if not sooner)
 CFPB must analyze impact of QM rule after 5 years, and may allow the temporary
provision to expire prior to sunset.
47
Small Creditor Balloon Qualified Mortgage
 Standard definition of QM generally excludes loans with balloon payments
 Special Small Creditor Balloon QM:
 Only by small (portfolio) creditors in rural/underserved areas
 Less than $2B in assets, originated more than 50% of transactions in
rural or underserved transactions, but fewer than 500 total (along with
affiliates)
 Loan not subject to forward commitment; if creditor sells, assigns, or
otherwise transfers loan it could immediately lose its Balloon QM
status
 No neg am
 Loan term does not exceed 30 years (but at least 5 years)
 Total points and fees do not exceed 3% (or different threshold for smaller
loans)
 Must consider and verify current or reasonably expected income/assets;
current debt obligations, alimony, and child support; but without regard to
App. Q
 Determine consumer can make all scheduled payments and mortgagerelated obligations excluding the balloon payment
 Consider DTI/residual income, excluding balloon (but no specific
limits/standards)
 Must otherwise have substantially equal scheduled payments calculated
based on amortization period that does not exceed 30 years
 Fixed rate
48
Break
Concurrent ATR/QM Proposed Rule
49
Concurrent Proposed Rule, cont.
Exemptions for HFA programs, nonprofit creditors,
EESA programs (Hardest Hit, etc.)
 Credit made pursuant to a program administered by a housing
finance agency (HFA)
 ATR requirements may undermine the underwriting
requirements of these programs, e.g., may require consideration
of underwriting factors that are not required under HFA
programs, such as the consumer’s credit history
 Also concerned that complying with the ATR requirements could
result in a severe curtailment of the credit offered under these
programs
50
Concurrent Proposed Rule, cont.
Exemptions for HFA programs, nonprofit creditors, EESA programs
(Hardest Hit, etc.)
 Creditors designated by Treasury as Community Development
Financial Institutions or by HUD as Community Housing
Development Organizations or Downpayment Assistance
Providers of Secondary Financing
 501(c)(3) nonprofits, provided (a) the credit is to a consumer
with income that does not exceed the qualifying limit for
moderate income families as established pursuant to section 8
of the United States Housing Act of 1937, (b) during the
preceding calendar year the creditor extended credit no more
than 100 times and only to consumers with income that did not
exceed the above qualifying limit, and (c) the creditor
determines, in accordance with written procedures, that the
consumer has a reasonable ability to repay the extension of
credit
51
Concurrent Proposed Rule, cont.
Exemptions for HFA programs, nonprofit creditors,
EESA programs
 Loans made pursuant to an Emergency
Economic Stabilization Act program, e.g., loans
under a State Hardest Hit Fund program. If had
to comply with ATR would:
 Make it more difficult for consumers to qualify for
assistance and increase the cost of credit for
those who do, impacting the availability of credit
for at-risk consumers
 Disrupt the financial market for consumers at risk
of foreclosure or default
52
Concurrent Proposed Rule, cont.
Proposed Exemption from Ability-to-Repay Requirement
for FHA/VA Refinancings
 Refinancings eligible to be insured, guaranteed,
or made pursuant to a program administered by
the FHA, VA, or USDA
 Same-creditor or third-party refi
 Temporary: Only until the respective federal
agency prescribes exemption rules
53
Concurrent Proposed Rule, cont.
QM for Small Portfolio Lenders and Small Creditors in
Rural/Underserved Counties
 Considering loans made by certain small
creditors and held in portfolio
 Must have total assets of $2 billion or less as of
the end of the preceding calendar year; and
 May not have originated more than 500 first-lien
loans covered by the ATR in the prior calendar
year (aggregated with affiliates)
 Can avoid following Appendix Q or the 43% DTI
limit in underwriting the loan, but must satisfy the
other QM requirements
54
Concurrent Proposed Rule, cont.
QM for Small Portfolio Lenders and Small Creditors in
Rural/Underserved Counties
 Small creditors operating predominantly in rural
or underserved areas may originate balloonpayment safe harbor QMs with APRs up to 3.5%
above the APOR
 Must originate 500 or < first lien, covered
transactions in the preceding calendar year, have
assets under $2 B, and make > than 50% of their
total first lien, covered transactions on properties
in rural or underserved counties (as defined)
55
Break
Prepayment Penalty Restrictions
56
RESTRICTIONS ON PREPAYMENT PENALTIES (PP)
A.
Covered Transaction Cannot Include PP Unless
1.
Penalty otherwise permitted by law
2.
APR cannot increase after consummation
3.
Loan is a QM (regular, temporary or balloon)
4.
Loan is not a “higher-priced covered transaction”
5.
Penalty cannot apply after third year following
consummation

Must not exceed 2% of outstanding loan balance
prepaid during first 2 years after consummation

Must not exceed 1% during third year after
consummation
57
B. Alternative Offer Required
1.
If lender offers loan product with PP
2.
Must also offer borrower an alternative with
similar features that does not contain a PP
3.
May not structure loan as open-end credit to
circumvent PP requirements
58
Record Retention
59
Record Retention
1.
Expands required record retention period from two years from
consummation to three, to match extended SOL for civil liability

Agencies have discretion to require longer retention

Bureau believes that responsible creditors will retain records
beyond three years because of risk of defensive claims
2.
Actual paper records not required, as long as records can be
reproduced
3.
No need to document compliance with the requirement to offer an
alternative transaction without a prepayment penalty when a
consumer does not choose a transaction with a prepayment penalty
or if the covered transaction is not consummated
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Liability/Penalties
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Liability / Penalties
 CFPB - Authority to issue cease and desist orders and
impose civil monetary penalties
 Private Right of Action – Affirmative action for actual
damages, statutory damages (individual and class actions),
costs and attorney fees, and special damages equal to all
finance charges and fees (unless failure not material)
 3 year statute of limitations
 No arbitration
 Foreclosure defense - By recoupment or set off
 No 3 year statute of limitations
 TILA damages, but special statutory damages limited to no more
than 3 years of finance charges and fees
 Applies to assignees
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Political Dynamics
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POLITICAL DYNAMICS
 A Balanced Approach?: Stakeholder
Reception
 Next Up: Pivoting to the QRM
 Policy Makers: The Current Political
Environment
 CFPB Director Cordray: Constitutional
Concerns
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