i serve as ceo of orion federal credit union in memphis, tennessee. we appreciate the opportunity to discuss the cfpbs ability to repay rule and the impact qualified mortgage standard will have an credit union lending. credit unions did not causes financial crisis and shouldn't be subject to the regulations aimed at those entities that did. unfortunately, it has not been the case thus far. as we're hearing from many of our credit union members enough is enough when it comes to the tidal wave of new regulations. we support efforts to support that lenders are not forced into marts they cannot afford. this is a long standing practice of credit unions before the crisis and continues to be the case post crisis. credit unions have a history of making loans for their members they have the ability to repay. this was demonstrated by the quality of their loans during the financial crisis. while credit union loans generally do not have a problem meetings ability to repay underwriting criteria, meeting the additional criteria to obtain a qm status and avoid the ad