Mortgage Insurance

Browse articles from all of our Newsletters related to Mortgage Insurance.

July 25, 2014 - Inside The GSEs

FHFA’s Proposed Mortgage Insurance Rules Tilt Market

New mortgage insurance eligibility rules proposed earlier this month by the Federal Housing Finance Agency appear likely to cause some MIs to tweak their corporate structures and/or to raise additional capital, note industry observers. In its draft Private Mortgage Insurer Eligibility Requirements, the FHFA directed Fannie Mae and Freddie Mac to revise, expand and align their risk management requirements for mortgage insurance counterparties.The updated financial requirements incorporate a new, risk-based framework that ensures that approved insurers have a sufficient level of liquid assets from which to pay claims.

July 24, 2014 - Inside Mortgage Finance

Most Lenders Rode Surge in Mortgage Production In 2Q14, But Pace Was Well Below Recent Past

A healthy housing recovery boosted mortgage origination volume during the second quarter of 2014, but production remains at relatively sluggish levels, according to a new market analysis and ranking by Inside Mortgage Finance. Single-family mortgage originations totaled an estimated $295 billion during the second quarter, up 25.5 percent from the first three months of the year. The first quarter of 2014 was the worst production environment for the mortgage industry since the end of 2000, even falling below the mark set at the depth of the financial crises in the fourth quarter of 2008. In fact, the most recent April-to-June cycle brought...[Includes three data charts]

July 21, 2014 - Inside the CFPB

Worth Noting/Looking Ahead/Vendor Update

Bureau Moves to Ensure Equal Treatment for Same-Sex Marrieds. The CFPB is synchronizing its internal policies with the U.S. Supreme Court decision in United States v. Windsor, striking down as unconstitutional Section 3 of the Defense of Marriage Act, which holds that the word ‘marriage’ means only a legal union between one man and one woman. According to a staff memorandum from CFPB Director Richard Cordray, the CFPB will regard a person who is married under the laws of any jurisdiction to be married nationwide for purposes of the federal statutes and regulations under the bureau’s jurisdiction regardless of the person’s place of residency. However, consistent with other federal regulatory agencies, the bureau will not regard persons who are joined ...

July 18, 2014 - Inside FHA Lending

Around the Industry

Senate Confirms Julian Castro as Next HUD Secretary. The Senate has confirmed Julian Castro as the 16th secretary of housing and urban development by a vote of 71 to 26. He replaces Secretary Shaun Donovan, whose nomination for director of the Office of Management and Budget was also approved 75-22 by the Senate on July 10. Before his nomination, Castro served three terms as mayor of San Antonio, TX, during which he focused on revitalizing the city through numerous housing and economic development initiatives. Housing advocates who have worked with Castro said, as a municipal leader, he knows what is needed to rebuild local economies under enormous financial constraints, which he can work to his advantage as HUD’s new head. In addition, Castro has the capacity and temperament to work with a Republican Congress, they said. The Securities Industry and Financial Markets Association said it looked forward to working with ...

July 18, 2014 - Inside FHA Lending

Infractions that Could Trigger MRB Enforcement

One deficiency commonly noted in cases heard by the Department of Housing and Urban Development’s Mortgagee Review Board is failure by FHA lenders and servicers to implement and maintain a quality control (QC) plan. FHA’s focus on quality control has increased over the last couple of years as the agency strives to correct underwriting flaws that have contributed to the massive losses and severe depletion of the Mutual Mortgage Insurance Fund. After years of guiding and helping clients comply and cope with FHA regulations, requirements and enforcement actions, the Collingwood Group reports that a common QC-related mistake among FHA lenders is failure to document steps taken to correct deficiencies – or to take any corrective action at all. Tied to this issue is ...

July 18, 2014 - Inside FHA Lending

Borrower OK Required to Voluntarily End Federal MI

New FHA guidance regarding voluntary termination of FHA mortgage insurance does not affect separate guidance requiring borrowers to continue payment of their annual insurance premium regardless of the loan’s amortization terms. The FHA made the clarification in relation to Mortgagee Letter 2014-13, which requires written consents by the lender and the borrower in all voluntary terminations of FHA mortgage insurance. The requirement becomes effective on Oct. 1st this year. Specifically, the guidance requires FHA lenders to document that they have obtained the borrower’s informed consent to terminate FHA insurance on the mortgage. The change ensures that the lender would incur no liability and that the borrower understands the terms of the voluntary termination. Under current rules, the FHA may terminate mortgage insurance at the request of the borrower and the lender. The lender may cancel the insurance endorsement upon notification by the FHA commissioner that the insurance contract is terminated.

July 18, 2014 - Inside FHA Lending

FHA to Lenders: Try PFS First Before DIL Option

If an FHA borrower runs out of options for loss mitigation and home retention, a lender must first consider a pre-foreclosure or short sale, with deed-in-lieu (DIL) of foreclosure as a second option, according to new FHA guidance. Mortgagee Letter 2014-5 states that the lender must first determine whether the borrower facing default or at risk of default qualifies for a pre-foreclosure sale (PFS). The FHA allows pre-foreclosure sales to be processed as either a “standard PFS” or a “streamline PFS.” The former is available only to owner-occupants while the latter is for both owner- and non-owner-occupied single-family properties. In determining standard PFS eligibility, the lender must use a “deficit income test” to determine whether the borrower is experiencing hardship and is able to sustain his or her mortgage. A DIT resulting in a negative amount would likely qualify the borrower for a ...

July 18, 2014 - Inside FHA Lending

JPMorgan Chief Seeks FHA Safe Harbor for Bank

JPMorgan Chase chief executive Jaime Dimon this week warned that the investment bank may rethink its FHA business without some type of safe harbor to shield it from potential future liabilities arising from the Financial Institutions Reform, Recovery and Enforcement Act and the False Claims Act. In February this year, JPMorgan agreed to pay $614 million to the federal government to settle allegations that it falsely certified poorly underwritten loans for FHA endorsement, causing massive losses to taxpayers in paid claims. Dimon lashed out at the government during a telephone briefing on the company’s second-quarter 2014 earnings report. He said JPMorgan lost a tremendous amount of money over what the government claimed was fraud but was in fact a “commercial dispute” between FHA and the bank. “We collected $600 million in insurance, the [government] disputed $200 million [alleging] it was fraud ...

July 18, 2014 - Inside FHA Lending

Endorsements Up for 620-679 Credit Scores

Mortgages with 620-679 credit scores accounted for more than half of FHA’s mortgage insurance business in the first quarter of 2014, up from 42.0 percent a year ago, according to the Department of Housing and Urban Development’s latest quarterly report to Congress on the state of the FHA Mutual Mortgage Insurance Fund. Data showed FHA-insured mortgages in the 620-679 credit score range, a band typically identified with borrowers with slightly tainted credit, comprised 51.1 percent of new endorsements in the first quarter. This was up from 50.1 percent in the fourth quarter of 2013. FHA endorsements in the 620-plus category started trending upward in the first quarter of 2011, while endorsements in the 720-850 credit score range began a slow decline during the same period. The distribution of borrower credit scores continued the migration seen in previous quarters, though at a ...

July 17, 2014 - Inside Mortgage Finance

FHFA MI Proposal Could Give a Competitive Edge To ‘Newbies,’ Narrow Gap With FHA Pricing

Private mortgage insurers that survived the housing market collapse are quietly gnashing their teeth over new eligibility rules proposed by the Federal Housing Finance Agency, which likely will cause some to reengineer their corporate structures and/or raise additional capital. The good news for the legacy firms – Genworth, Mortgage Guaranty Insurance Corp., Radian and United Guaranty – is that they have the financial ability to meet the new capital standards. The bad news – for this group and MI newcomers – is that the FHFA’s proposals would narrow the competitive gap between the private MIs and the FHA. One trade group official, speaking under the condition his name not be used, noted...

July 11, 2014 - Inside The GSEs

Freddie Announces Second ACIS Deal of 2014, Largest to Date

Freddie Mac last week announced its second Agency Credit Insurance Structure of 2014, through which it buys insurance to lay off risk. The GSE said its purchase of a number of insurance policies designed to cover some $285 million in potential losses from a pool of single-family loans acquired in the second quarter of 2013 was its largest credit risk transaction to date. …

July 11, 2014 - Inside The GSEs

New GSE Mortgage Insurance ‘Stand-In’ Takes Effect

Last week, new GSE repurchase requirements announced this spring took effect as a potential alternative to repurchase for certain mortgage loans for which the mortgage insurance has been rescinded. Among the requirements are an “MI stand-in,” which Fannie Mae defines as “the full mortgage insurance benefit that would have been payable under the original mortgage insurance policy if the mortgage loan liquidates.” In May, both Fannie and Freddie Mac announced that repurchase requests will no longer be an automatic response in the event that MI is rescinded.

July 11, 2014 - Inside The GSEs

FHFA Unveils ‘Eligibility’ Standards For Mortgage Insurance Firms

The Federal Housing Finance Agency late this week finally unveiled new eligibility standards for the mortgage insurance industry, introducing for the first time risk-based capital rules that are tied to a measurement called “available assets.” Immediately after the rule hit the market, several MI firms said they support the idea that Fannie Mae and Freddie Mac must have strong financial counterparties, while hinting they will have more to say on the topic in the near future.

July 10, 2014 - Inside Mortgage Finance

Lender: New GSE Mortgage Insurance ‘Stand-In’ Does Nothing to Reduce Buyback Uncertainty of Legacy Loans

Recently implemented steps by the two government-sponsored enterprises to provide an alternative to repurchase when mortgage insurance is rescinded is a pleasant salve for a minor ailment, but it does nothing to address lenders’ chronic pain of sudden and unexpected buyback demands, according to a mortgage lender. Last week, new GSE repurchase requirements took effect, including the “MI stand-in” option, which Fannie defines as “the full mortgage insurance benefit that would have been payable under the original mortgage insurance policy if the mortgage loan liquidates.” In May, both Fannie and Freddie announced...

July 10, 2014 - Inside Mortgage Finance

Fannie Mae and Freddie Mac Securitize Hefty Crop of Privately-Insured Mortgages in 2Q14

The modest rebound in the housing market during the second quarter of 2014 produced a solid increase in the volume of home loans with private mortgage insurance securitized by Fannie Mae and Freddie Mac. A new Inside Mortgage Finance analysis and ranking reveals that the two government-sponsored enterprises securitized $37.36 billion of single-family mortgages with private MI coverage during the second quarter. That was up 24.7 percent from the first three months of the year, which had produced a dismal $29.95 billion of MI-insured loans in new GSE mortgage-backed securities. By comparison, total GSE business was...[Includes two data charts]

July 3, 2014 - Inside FHA Lending

Around the Industry

Senate Banking Committee Approves HUD, FHFA IG Nominees. The Senate Committee on Banking, Housing and Urban Affairs recently approved the nomination of Julian Castro as the next secretary of the Department of Housing and Urban Development. Castro, D, is the incumbent mayor of San Antonio, TX. The panel also approved the nomination of Laura Wertheimer as inspector general of the Federal Housing Finance Agency. The Senate has yet to confirm their nominations. Meanwhile, HUD Secretary Shaun Donovan’s nomination for director of the Office of Management and Budget was approved by the Senate Committee on Homeland Security and Governmental Reform on June 25. FHA Policies on Arm’s Length Transactions and Compliance with State Laws. The FHA is developing guidance to address concerns that laws in certain states may conflict with its arm’s length transaction requirements for preforeclosure/short sales. Until the guidance is issued, FHA lenders should seek guidance and assistance from the FHA National Servicing Center in matters of ...

July 3, 2014 - Inside FHA Lending

FHA Requests Feedback on Handbook Sections

The FHA is seeking comment on two new sections of a proposed single-family handbook for mortgage lenders. The handbook is in development. Once completed, it will serve as the centralized source of current and future FHA policies. Agency staff is collating policies from several handbooks, rules, mortgagee letters, notices and other sources to incorporate into the handbook. The FHA is publishing two new sections, “Doing Business with FHA – FHA Lenders and Mortgagees” and “Quality Control, Oversight and Compliance,” for comment. The “Doing Business” section lays out the requirements for FHA lender approval, including eligibility requirements, application processes, operating requirements and post-approval changes. The section also contains the recertification process as well as processes for applying for ...

July 3, 2014 - Inside FHA Lending

FHA Adds Non-Borrowing Spouses to HECM PLFs

The FHA has announced new principal limit factors (PLF) for Home Equity Conversion Mortgages along with instructions to lenders to ensure that borrowers and their non-borrowing spouses understand the benefits and disadvantages of a reverse mortgage. The new PLF tables have been wholly revised and now include PLFs for use where the borrower has a non-borrowing spouse younger than age 62. In recent guidance, the FHA urged lenders to ensure that borrowers are provided with an analysis of the cost of a HECM loan and its benefits so that they can decide whether a reverse mortgage would meet their financial needs. Lenders also must advise prospective borrowers and their non-borrowing spouses to consult with a housing counselor whether PLFs below 20 percent may or may not actually improve their financial situation or meet their special needs. “Significant consideration should be given to the ...

July 3, 2014 - Inside FHA Lending

FHA Lenders Raise Production Numbers in April

FHA lenders reported a significant increase in the number of FHA-insured loans originated in April, breaking a downward production spiral that began in the third quarter of last year. Whether this marks a turnaround for the market, however, is uncertain. April closed with $10.3 billion in total FHA originations, up 18.5 percent from March but down 51.7 percent from the same period a year ago. This surge in FHA financing occurred despite the rising costs of obtaining an FHA loans and access-to-credit issues, which have narrowed the gap between FHA and conventional loans with private mortgage insurance. Spring and Fall are the busiest times of year for home sales which might explain the spike, according to real estate agents. FHA fixed-rate mortgages comprised 95 percent of April’s production, with purchase loans accounting for 78 percent of loans originated during the month. FHA lending trends, however, show ... [2 charts]

July 3, 2014 - Inside FHA Lending

Lenders Find Glitches in Fledgling LEAP 3.0

It has been barely a month since the FHA deployed its Lender Electronic Assessment Portal (LEAP 3.0), but lenders are already having difficulty executing some functions in the new system. Lenders are complaining about how hard it is to provide access to independent public accountants (IPA) for purposes of recertification functions, as well as difficulties in making changes to existing branches or adding new ones or changing cash flow accounts. Lenders are concerned they may be sanctioned or penalized if they make a mistake, but the FHA seems not inclined to do this because the system is new. “[We] are highly focused on correcting these issues, and hope to have these functions working properly very soon,” the agency promised in a recent note to FHA lenders. The FHA said it is also aware of the complications that some lenders have faced in submitting their annual recertification in LEAP. Many of these problems have been addressed and the deadline for submission of recertification packages has been extended as well, the agency noted.

July 3, 2014 - Inside FHA Lending

Agencies Take Down Another FHA Lender

U.S. Bank became the latest casualty in the government’s offensive against lax underwriting and improper origination of FHA mortgages after the bank to pay $200 million to settle all related charges. The Minneapolis-based bank became the seventh FHA lender since 2012 that has entered into settlement agreements with the Department of Justice and the Department of Housing and Urban Development to resolve alleged violation of the False Claims Act and the Financial Institution Reform, Recovery and Enforcement Act, according to Inside FHA Lending’s analysis of government data. The government lawsuits allege that the banks’ certification of loans as eligible for FHA insurance under the direct endorsement program violated the FCA. The banks’ misconduct allegedly contributed to the legacy losses that crippled the FHA Mutual Mortgage Insurance Fund and placed the ...

July 3, 2014 - Inside Mortgage Finance

House to Push Permanent PMI Tax Break Bill While Senate ‘Extender’ Legislation Stalled Until Elections

Look for the Republican-controlled House this month to push additional “tax extender” legislation, including a measure to make permanent a tax break for private mortgage insurance, although the Senate will likely defer any action on tax bills stalled until after the November elections. More than six months after a series of tax incentives, including some mortgage-related measures, expired due to Congressional inaction, partisan sniping and a distinct difference in the legislative approaches of House and Senate tax-writing chairmen has contributed to uncertainty within the industry. House, Ways and Means Committee Chairman Dave Camp, R-MI, has taken...

July 3, 2014 - Inside Mortgage Finance

With Loss Mitigation Actions Declining for Banks and Nonbanks, HAMP Extended

Loss mitigation activity continued to decline in the first quarter of 2014, driven by better loan performance. That didn’t stop the Treasury Department from extending the Home Affordable Modification Program and related loss mitigation programs for at least another year, through the end of 2016. A total of 132,783 loan modifications were completed in the first quarter, according to Hope Now, down 3.4 percent from the previous quarter and down 45.7 percent from the first quarter of 2013. On a monthly basis, loan mod activity continued to decline in April. Loan mod activity is...

July 3, 2014 - Inside Mortgage Finance

FHFA Readies Capital Rules for Mortgage Insurers; Parent Companies May Have to Put Assets Into Subs

The Federal Housing Finance Agency will soon unveil capital rules for private mortgage insurers, introducing a risk-based standard based on loan-to-value ratios and other factors, while requiring parent companies to pledge assets to their MI subsidiaries if necessary, according to officials close to the matter. “Financial strength will be measured by comparing insured risk, on a risk-adjusted basis, against available assets,” said one official commenting under the condition he not be identified. The phrase “available assets” is key because it portends that liquidity must reside at the MI level and not at an affiliate of a parent company. It’s...

June 27, 2014 - Inside The GSEs

OIG: FHFA Should Sue To Recover LPI Overcharges on GSE Coverage

A new audit released this week by the Federal Housing Finance Agency’s official watchdog found that Fannie Mae and Freddie Mac suffered $158 million of “financial harm” due to excessively priced lender-placed or “force-placed” insurance policies in 2012 alone. The FHFA-OIG audit notes that several state financial regulators found that the LPI rates in their states were excessive. The excessive costs were driven up by “profit-sharing arrangements under which servicers were paid to steer business to LPI providers. Such arrangements often took the form of commission structures and reinsurance deals,” according to the OIG.

June 26, 2014 - Inside Mortgage Finance

IG Audit: Fannie, Freddie Overcharged at Least $158M For ‘Force Placed’ Insurance, FHFA Should Sue to Recover

The Federal Housing Finance Agency will “assess the merits of litigation” against Fannie Mae’s and Freddie Mac’s servicers and lender-placed insurance providers to recover premium overpayments by the government-sponsored enterprises following a pointed suggestion to do so by the agency’s official watchdog. A new audit released by the FHFA’s Inspector General found that Fannie and Freddie could have overpaid about $158 million in 2012 alone for lender-placed or “force-placed” insurance policies. The IG said it calculated its $158 million figure as the difference between the amount the GSEs actually paid in premiums – $360 million – and a “reasonable” price for such coverage – $202 million. “Our retrospective analysis suggests...

June 20, 2014 - Inside FHA Lending

Around the Industry

NY Passes Bill to Reduce Number of FHA Loans that Would Fall Under Subprime. The New York Assembly recently passed legislation that would result in fewer FHA loans being classified as “subprime” under state banking law, according to the law firm Ballard Spahr. Already passed by the Senate, the bill would make permanent prior emergency rules issued by the Department of Financial Services, which raised the subprime threshold 75 basis points for those loans subject to the revised FHA mortgage-insurance premium cancellation policy. Although the emergency rules were set to expire on Dec. 31, 2013, the DFS granted an extension to allow the state legislature additional time to find a permanent solution, said Ballard Spahr attorneys. The bill passed with overwhelming bipartisan support and strong industry backing, and is expected to ...

June 20, 2014 - Inside FHA Lending

FHA Jumbo Production Continues Slide in 1Q14

FHA jumbo loan originations fell significantly in the first quarter of 2014 due primarily to higher mortgage insurance premiums and a decrease in the mortgage loan limits, particularly in high-cost areas of the country, according to Inside FHA Lending’s analysis of agency data. FHA lenders reported a meager $2.4 billion in jumbo originations during the first three months of the year, a decrease of 21.2 percent from the previous quarter and down a whopping 55.7 percent from the same period a year ago. Purchase loans accounted for 81.0 percent of new originations while fixed-rate loans comprised 86.8 percent. FHA jumbo loans are those over $417,000 and they comprise a very small slice of the FHA’s overall loan portfolio. Citing FHA data, Brian Chappelle, a mortgage industry consultant, said that of the FHA loans originated in the last 12 months, roughly 11,000 loans were above $500,000, down from ... [ 2 charts]

June 20, 2014 - Inside FHA Lending

Public Support Building for HUD’s HAWK Pilot

The FHA’s Homeowners Armed With Knowledge (HAWK) pilot program is getting strong public support, particularly from first-time homebuyers and housing counselors.Based on comments received by the Department of Housing and Urban Development so far, the HAWK pilot is already taking hold in the public’s mind despite its limited publicity. -Rachel Andreyo, a new college graduate who was turned down recently for a mortgage loan pre-approval, said HAWK not only would educate potential first-time homebuyers about homeownership but also raise their hope of becoming a homeowner before the age of 30. “The knowledge this program would provide could be a game changer for young people and struggling Americans everywhere,” she wrote. Shawanda Walker, a single mother, sees HAWK as an opportunity for her to learn how to negotiate her first home purchase, learn about property taxes and ...

June 20, 2014 - Inside FHA Lending

NAR Seeks Changes to FHA Performance Metric

The FHA’s proposed supplemental method for measuring lender performance is “a step in the right direction” and would help compare lenders to an FHA acceptable rate, rather than an industry average, according to the National Association of Realtors. The supplemental performance metric is crucial in an environment where lenders are instituting credit overlays on FHA-insured mortgages, the NAR said in a comment letter. The FHA proposes to use the metric along with the compare ratio to determine whether a lender with an unusually high default rate should be terminated from the FHA single-family program. This reflects the FHA’s view that factors other than the compare ratio might also influence a lender’s performance. Currently, the FHA compares a lender’s early seriously delinquent (SDQ) performance in a geographic area to other lenders in the same area. The number derived from this ...

June 20, 2014 - Inside FHA Lending

Castro Sails Smoothly Through Nomination Hearing

Barring any unpleasant news, Julian Castro, President Obama’s nominee for secretary of the Department of Housing and Urban Development, apparently has passed his job interview with the Senate Banking, Housing and Urban Affairs Committee. This week, Castro, a three-term mayor of San Antonio, TX, laid out his priorities as HUD secretary before committee members if he is confirmed for the job. Castro underscored the importance of “partnership and pragmatism” as the key drivers in running a city. As HUD secretary, Castro said he would enhance “cross-agency collaboration” and emphasize the value of “measuring results” by setting precise goals, consulting with the public on major issues, developing a public report card and annual updates – tools he employed in his municipal housing education and affordable housing initiatives in San Antonio. As mayor, Castro worked to ...

June 20, 2014 - Inside FHA Lending

Agencies Crack Down on False Ads, Marketing

Two federal agencies have announced separate actions to protect reverse mortgage borrowers and rural home purchasers from deceptive advertising and marketing. This week, the FHA warned lenders participating in the Home Equity Conversion Mortgage program not to use misleading or deceptive language in marketing FHA-insured reverse mortgages to consumers. The FHA said the guidance is intended to protect HECM borrowers from advertising and presentations that appear to limit their options rather than informing them of the full range of available HECM products. Underscoring senior borrowers’ “freedom of choice,” FHA Commissioner Carol Galante said the agency wants lenders to know their marketing and advertising practices are under constant surveillance to prevent customers from being steered to unsuitable reverse mortgage products. Galante noted the ...

June 20, 2014 - Inside FHA Lending

Lenders Feel ‘Unsafe’ Dealing with FHA

SunTrust Mortgage’s recent settlement of a dispute with the federal government and 49 state attorneys general over defective FHA loans and Wells Fargo’s losing bid to quash a similar lawsuit are raising concerns about doing business with the FHA. Industry attorneys say the lesson for lenders in these recent industry debacles is that it is “extraordinarily dangerous” to do FHA loans these days given the outcome of the two cases. It is also getting harder to trust mortgage settlement agreements with the government, they added. “The scariest part in all these is the combination of government forces involved in these claims – state AGs, Department of Justice, Department of Housing and Urban Development and the Consumer Financial Protection Bureau,” said an attorney, who worked on both cases. “When they want to get you, they can get you.” Others believe these developments could have a ...

June 19, 2014 - Inside Mortgage Finance

HUD Nominee Castro Says the Right Things, Provokes No Opposition During Senate Nomination Hearing

Barring the discovery of a skeleton in his closet, Julian Castro’s nomination for secretary of the Department of Housing and Urban Development appears to be a lock in the Senate Committee on Banking, Housing and Urban Affairs. Appearing before the committee this week, Castro, a three-term mayor of San Antonio, TX, laid out his priorities for HUD if confirmed. He said he would emphasize working closely with agencies as well as the value of “measuring results” by setting precise goals, public consultation, development of a public report card and annual updates – tools he employed in his municipal housing education and affordable housing initiatives in San Antonio. Castro said...


Home-equity lending is beginning to show new life. My company (pick one):

Plans to enter this market over the next 12 months.
Is already making home equity loans and hopes to increase the offerings.
Is in the market but don’t expect much growth.
Is not making second liens and has no plans to do so.

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