The Mortgage Bankers Association, in written testimony, says the proposed QRM definition "is so restricted that 80% of loans sold to Fannie Mae or Freddie Mac over the past decade would not meet these requirements." According to the National Association of Realtors, drawing upon national savings rate data, "it would take 9.5 years for the typical American family to save enough money for a 10% down payment and closing costs, and fully 16 years to save for a 20% down payment and closing costs." "A 10% or 20% down payment requirement for the QRM means that even the most creditworthy and diligent first-time homebuyer cannot qualify for the lowest rates and safest products in the market," an NAR statement reads, adding that such a move will "be placing homeownership out of reach for millions of potential buyers and crippling an already fragile housing recovery." "Weak underwriting and toxic mortgages are the main cause of mortgage defaults, not well-underwritten mortgages that allow for low down payments," reads a letter circulated to government officials by opponents of the down payment hike. There is a financial incentive for lenders to push back against tougher QRM standards. The Dodd-Frank Act requires financial institutions that securitize mortgage loans to retain at least 5% of the credit risk. It exempts securities backed exclusively by QRMs from the risk-retention requirement, lowering the cost of securitizing these mortgages, as they are considered to hold less risk. Narrowing the scope of what qualifies will mean homebuyers need to meet tougher standards. If fully implemented, other Dodd-Frank related provisions could mean limiting the mortgage payment to 28% of gross income and limiting all debt to 36% as part of the mortgage qualification process. No credit score requirement is currently mandated, but a mortgage loan would qualify as a QRM only if the borrower is not 30 or more days past due on any debt obligation, or 60 or more days past due on any debt obligation within the preceding 24 months. Borrowers who, within a span of 36 months, have been through bankruptcy, foreclosed on, engaged in a short sale or deed-in-lieu of foreclosure, or been subject to a federal or state judgment for collection of any unpaid debt would also not qualify.