Some have urged the Board to adopt this broad principle as a rule, while others have urged the Board to preserve for lenders the flexibility to exercise their judgment in determining the likelihood that a given borrower can repay a loan.
While it seems self-evident that adequate consideration of repayment ability is necessary, our experience in crafting the guidance taught us that this principle is far easier to articulate in general terms than in detailed, prescriptive rules stating which underwriting practices constitute "adequate" consideration.