Regulations

Browse articles from all of our Newsletters related to Regulations.

November 24, 2014 - Inside the CFPB

Worth Noting

CFPB eClosing Program Will be a Plus, Eventually. The eClosing initiative launched earlier this year by the CFPB will ultimately be beneficial to the mortgage industry, once all the big wrinkles are ironed out, according to analysts at DBRS, formerly Dominion Bond Rating Service. “Many of the elements that make up eClosings are already being used in other consumer and commercial loans (such as auto loans and equipment lending), so much of the process should be easy to replicate,” the analysts said in a client note last week. “However, it is the uniqueness of the mortgage industry that will present some challenges.” For instance, there are real estate statutes for real property, compared with the Uniform Commercial Code for personal ...


November 24, 2014 - Inside the CFPB

CFPB Needs to Make More Info Security Upgrades, OIG Finds

The CFPB’s Office of Inspector General found the bureau’s information security program was generally in compliance with the Federal Information Security Management Act, but that further improvements are needed in security training and contingency planning. Nine other areas that received a passing grade from the OIG were information security continuous monitoring (ISCM), configuration management, identity and access management, incident response and reporting, risk management, plan of action and milestones, remote access, contractor systems, and security capital planning. “While we found that the CFPB’s information security program was generally consistent with the requirements for ISCM, configuration management, and incident response, we identified opportunities to strengthen these areas through automation and centralization,” the report stated. This year, the OIG found that the ...


November 24, 2014 - Inside the CFPB

GAO Finds Weakness in CFPB Internal Control for Payables

The CFPB’s internal control over financial reporting was not effective as of September 30, 2014, because of a material weakness related to the reporting of accounts payable, according to a new study by the U.S. Government Accountability Office. The material weakness is a result of serious control deficiencies that affected CFPB’s determination and reporting of accounts payable. “Specifically, GAO found that CFPB did not have effective procedures in place to determine and record an appropriate amount for goods and services received but not yet paid for as of Sept. 30, 2014,” said the congressional watchdog agency. Additionally, CFPB did not have effective review procedures to timely detect and correct inaccuracies in the accrual amounts. “Despite the material weakness, CFPB made ...


November 25, 2014 - IMFnews

GSE Loan Limits Mostly the Same Next Year, but Higher in 46 Counties

An unspecified number of counties would have been assigned lower loan limits, based on house price trends, but the FHFA weighed “other factors” and left them unchanged.


November 24, 2014 - Inside the CFPB

Consumer Complaints About Money Transfers Down Noticeably in 3Q14

Consumer complaints to the CFPB about their money transfer transactions fell a sharp 28.4 percent industry-wide during the third quarter of 2014, according to a new analysis by Inside the CFPB. From a short-term perspective, that’s a fairly good performance. The longer-term results are more iffy. The CFPB only started collecting complaints from this sector in the second quarter of 2013, so there are just a handful of reporting periods that can be reviewed. That being said, comparing two six-month periods – the second and third quarters of 2013 versus the same periods this year – the data show an industry-wide jump of 93.7 percent. On the other hand, there are only 1,409 total complaints that have been received [with exclusive chart] ...


November 24, 2014 - Inside the CFPB

Settlements with Ocwen, Flagstar, SunTrust Instructive for Servicers

The mortgage servicing settlements the CFPB obtained with Ocwen, SunTrust Bank and Flagstar Bank have much to teach the rest of the industry about landmines to avoid. During a webinar sponsored last week by Inside Mortgage Finance, an affiliated newsletter, Allyson Baker, a former CFPB attorney and partner at the Venable law firm in Washington, DC, highlighted the importance of trends seen in the three enforcement cases. “Number one is the bureau’s and other law enforcement agencies’ ongoing joint monitoring of the space,” which suggests the industry is likely to see more joint enforcement actions in the future, Baker told event participants. The second important trend is the very large civil money penalties and restitution that are resulting in tens ...


November 24, 2014 - Inside the CFPB

AFSA Study Disputes Bureau’s Indirect Auto Finance Methodology

A new study commissioned by the American Financial Services Association found significant bias and high error rates in the proxy methodology used by the CFPB to determine discrimination in the indirect auto finance market. Central to the study was an examination of the Bayesian Improved Surname Geocoding (BISG) proxy methodology used by the CFPB to determine a disparate impact to legally protected groups. BISG estimates race and ethnicity based on an applicant’s name and census data. AFSA’s study calculated BISG probabilities against a test population of mortgage data, where race and ethnicity are known. One of the primary findings was that when the proxy uses an 80 percent probability that a person belongs to an African American group, the proxy ...


November 24, 2014 - Inside the CFPB

Bureau Warns Mortgage Lenders Against SSDI Discrimination

The CFPB put out a bulletin last week advising lenders not to create illegal hurdles for recipients of Social Security Disability Income who apply for mortgages, warning that requiring unnecessary documentation from such consumers could raise fair lending risk. The new bulletin discusses standards and guidelines on verification of SSDI, including those under the CFPB’s ability-to-repay rule, the Department of Housing and Urban Development’s standards for FHA loans, the Department of Veterans Affairs’ standards for VA-guaranteed loans, and guidelines from Fannie Mae and Freddie Mac. The bureau begins by noting that to verify income for qualified mortgage debt-to-income ratios under the ability-to-repay rule, lenders are required to look at whether the Social Security Administration benefit verification letter or equivalent document ...


November 24, 2014 - Inside the CFPB

Sweeping Changes for Prepaid Cards Under CFPB Proposal

The CFPB last week proposed sweeping changes for the booming prepaid card market, aiming to mandate new disclosures, error-resolution procedures, consumer liability limits for unauthorized transactions, fee limits, and added requirements for cards with overdraft or credit features. This proposal would apply a number of specific federal consumer protections to broad swaths of the prepaid market for the first time. The proposal would cover traditional plastic prepaid cards, many of which are general purpose reloadable cards. In addition, the proposal would cover mobile and other electronic prepaid accounts that can store funds. The prepaid products covered by the proposal also include: payroll cards; certain federal, state and local government benefit cards such as those used to distribute unemployment insurance, child ...


November 24, 2014 - Inside the CFPB

CFPB Fines Subprime Auto Dealer Over Debt Collection Practices

Last week, the CFPB initiated its first enforcement action against a “buy-here, pay-here” car dealer, DriveTime, which it accused of harming consumers by allegedly making harassing debt collection calls and providing inaccurate credit information to credit reporting agencies. DriveTime must pay $8 million as a civil money penalty, end what the bureau characterized as unfair debt collection tactics, revise its credit reporting practices, and arrange for harmed consumers to obtain free credit reports. Phoenix-based DriveTime Automotive Group Inc. and its finance company, DT Acceptance Corp., make up the largest buy-here, pay-here car dealer in the nation, according to the CFPB. “Buy-here, pay-here” means that the dealer sells the car as well as originates and services the auto loan. These kinds ...


November 25, 2014 - IMFnews

CFPB’s New Servicing Amendments Include Some Serious Tweaks to Force-Placed Insurance

Under current rules, a servicer cannot explain on the notice itself that the borrower’s hazard insurance is insufficient rather than expired or expiring...


November 24, 2014 - Inside the CFPB

CFPB Orders Franklin Loan Corp. to Pay Borrowers $730k in Restitution

The CFPB recently ordered Franklin Loan Corp., an independent, residential mortgage banker in Palm Desert, CA, to pay $730,000 to consumers the bureau alleges were harmed by the company’s practice of giving employees bonuses for steering consumers into loans with higher interest rates. The bureau also has asked a federal district court to approve a consent order requiring the company to end its allegedly illegal compensation system and refund the consumers it harmed. This is the second loan originator compensation settlement the CFPB has obtained, the first being the case involving Castle & Cooke Mortgage. In this case, according to the CFPB, Franklin Loan originated approximately $887 million in loans between 2011 and 2013. “From June 2011 to October 2013, ...


November 24, 2014 - Inside the CFPB

Numerous Other Servicing Changes Proposed in CFPB Amendments

There are eight other subject areas included in the CFPB’s 490-page proposed rulemaking to amend its 2013 mortgage servicing rules, above and beyond the extensive amount of revisions to loss mitigation practices, as highlighted above. The first of those has to do with successors in interest – people who inherit or receive property when there is still an outstanding mortgage loan on the property. The bureau is proposing three sets of rule changes relating to successors in interest, the first of which is to apply all of its mortgage servicing rules to a successor in interest once a servicer confirms that a person is a successor in interest. Second, the bureau is proposing rules relating to how a mortgage servicer makes ...


November 24, 2014 - Inside the CFPB

CFPB Propose Loss Mit Changes to 2013 Mortgage Servicing Rules

If anyone in the housing finance industry thought the CFPB was finished with its mortgage-related rulemaking, they were wrong. Last week, the CFPB issued a batch of proposed amendments to its 2013 mortgage servicing rules, including a number of changes to how servicers handle loss-mitigation applications. First, the bureau is proposing to require servicers to meet the loss-mitigation requirements of its mortgage servicing rules more than once in the life of a loan for borrowers who become current after a delinquency. However, the rule is not clear how many times this could occur over the life of the mortgage. A little insight can be gleaned from a CFPB blog posting geared towards borrowers, which stated, “We are also proposing that ...


November 25, 2014 - IMFnews

Hope for Mortgage-Related Tax Extenders?

The Mortgage Forgiveness Debt Relief Act allows homeowners who received principal reductions or other forms of debt forgiveness to avoid paying taxes on the amount forgiven.


November 24, 2014 - IMFnews

Short Takes: No More Thanksgiving Rally for GSE Shares / Sterne Agee Sees Little Optimism in ASPS / Mortgage Network Expands / RBS Kisses Mortgage Trading Desk Goodbye

Regarding Altisource Portfolio Solutions, Sterne Agee noted: “It is difficult to be optimistic from here"...


November 21, 2014 - Inside FHA Lending

Strong 3Q Pushes Up FHA’s Nine-Month Total

FHA lenders capped a nine-month production run with a total of $99.39 billion in forward mortgages, thanks to a strong push in the third quarter of 2014, according to Inside FHA Lending’s analysis of agency data. Third-quarter production totaled $38.3 billion, up 16.6 percent from the previous quarter. Year-over-year originations, however, were off by 43.0 percent. FHA endorsements have now fallen from a peak of 1.8 million loans in FY 2009 to approximately 786,000 in FY 2014, according to the latest independent actuarial review of the health of the Mutual Mortgage Insurance Fund. The 57 percent reduction in endorsements takes FHA closer to the lower levels of activities seen just prior to the housing bubble, the report noted. A sharp decline in refi activity drove the substantial drop in forward loan endorsements in fiscal 2014. Previously, many homeowners ... [1 chart]


November 21, 2014 - Inside FHA Lending

FHA Short Refi Production Declines in 2014

The number of underwater borrowers seeking to refinance their conventional mortgages into an FHA loan fell in fiscal 2014 from the previous year, according to an Inside FHA Lending analysis of agency data. The number of endorsements under the FHA Short Refinance program totaled 1,327 at the end of fiscal 2014, down from a record 1,662 in the prior year. Endorsements hit their peak in fiscal 2013. A total of 5,140 distressed conventional loans with a combined original mortgage amount of $784.9 million were refinanced under the program over the five-year period. In order to participate, borrowers must be current on their mortgage payments, have a credit score of 500 or greater and owe at least 15 percent more on the property than their home is actually worth. Lender participation is strictly voluntary. More importantly, the lender or investor must be ...


November 21, 2014 - Inside FHA Lending

GNMA Eyes Stronger Oversight of Nonbank Issuers

Ginnie Mae is seeking comment on several proposed data collections, including those that would strengthen the agency’s ability to monitor participants in its mortgage-backed securities programs. Due to its growing concern over the influx of non-depository issuers into the single-family MBS program, Ginnie has proposed to collect more loan-level data to supplement the information already being collected and reported on a monthly basis. The proposed data collection consists of bankruptcy-related information (action type, case identifier, chapter type, bar date) as well as borrower-related information (borrower bankruptcy indicator, classification type, total mortgaged properties, counseling initiated indicator and credit score date). Other proposed new data include document custodian ID, type of insurance claim coverage, investor unpaid principal balance (UPB), adjustment to ...


November 21, 2014 - Inside FHA Lending

Congress Urged to Extend Expiring VA Loan Limits

Thousands of military veterans in high-cost areas may be deprived of VA’s home-loan guarantee benefits unless Congress extends the current VA loan limits before the end of the year. Those loan limits expire on Dec. 31, 2014. The VA loan limits are based on median home values estimated by the FHA, providing loans up to 125 percent of local area median price. The program does not set a cap on how much a veteran can borrow to finance a home purchase but it does limit the maximum amount it can guarantee to 25 percent of the current loan limit. Veteran and industry groups are urging Congress to make the VA limits permanent. A VA spokesperson said the agency was not asked for a position on the issue since Congress did not put forward any bill in any of the hearings this year. “But as a general rule, VA wants to maximize the opportunities ...


November 21, 2014 - Inside FHA Lending

Wells Fargo, DOJ Settlement Talks Hit Wall

Wells Fargo and the Department of Justice are reportedly at an impasse in their settlement talks in connection with a lawsuit accusing the bank of improper underwriting and false certification of certain FHA-insured loans. In an e-mailed statement to Inside FHA Lending, a bank spokesperson said Wells Fargo’s good faith effort to work with the federal government to resolve the complaint “has not yet resulted in a settlement.” Nonetheless, the bank “will move forward with presenting [its] case in support of [its] prudent and responsible FHA lending practices, which have produced high-quality FHA loans with delinquency rates that are half the industry average,” the spokesperson added. This week, citing an unidentified source, Bloomberg reported that lawyers for the government and the bank have told the presiding judge in the case that they ...


November 21, 2014 - Inside FHA Lending

HECM Portfolio Down to Negative in FY 2014

The economic value of the FHA’s Home Equity Conversion Mortgage legacy portfolio fell to negative $0.9 billion in fiscal 2014 due mainly to volatility in long-term house prices and interest rates, according to the latest independent actuarial report on the health of the Mutual Mortgage Insurance Fund. The latest result was a significant improvement from FY 2012, when the fund stood at negative $2.8 billion. In fiscal 2013, the HECM portfolio’s economic value of positive $6.5 billion appeared to be a whopping change from the previous year but that amount reflected a $4.6 billion cash infusion from the forward program and from the $1.7 billion mandatory appropriation, the report clarified. The report also showed a corresponding decline in the HECM capital ratio to negative 1.20 percent. Actuarial projections for fiscal 2015 place the HECM portfolio’s economic value at negative $1.1 billion. The fund’s capital resources for ...


November 21, 2014 - Inside FHA Lending

MMIF Value, Capital Ratio Turns Positive

FHA Mutual Mortgage Insurance Fund ended fiscal 2014 in the black but was still far short of its statutory reserve requirement, prompting critics in Congress to renew their cries for FHA reform. An independent actuarial report sent to Congress this week showed that the MMI Fund now stands at $4.8 billion after a gain of nearly $6 billion over the last year. For the first time since 2009, the fund’s capital ratio also crossed into positive territory at 0.41 percent, up 52 basis points from the negative 0.11 percent posted in fiscal 2013. Overall, the economic value of the fund has risen by $21 billion over the last two years because of the aggressive steps the agency took to stabilize and strengthen the fund, the report said. Policy changes led to improved underwriting for single-family mortgages, increased mortgage insurance premiums, stronger loss mitigation policies and higher recoveries, it added. In addition, with ...


November 24, 2014 - IMFnews

Is the RMBS Outlook Glass Half Empty or Half Full?

“It’s been seven years since the financial crisis, and certainly a lot of things have changed,” said Rui Pereira, managing director at Fitch Ratings.


November 21, 2014 - IMFnews

What We’re Hearing: Higher FHA Costs, Not Lower / The GOP in Favor of This Tax Hike? / How About Regulating Nonbank Lenders? / Cyprus? Wilbur Ross Really is a Bottom Fisher / Ocwen Isn’t the Only Servicer That Loves India

There’s a growing fear that the CSBS might move to increase capital standards for nonbank originators as well.


November 21, 2014 - Inside MBS & ABS

Regulatory, Homeland Pressures Prompt RBS to Exit US Mortgage-Backed Securities Market

The Royal Bank of Scotland is shutting down its U.S. mortgage trading desk as it proceeds with a new plan to reposition its U.S. business. The announcement came after RBS reconsidered its initial plan disclosed five months ago to pare the mortgage trading unit by two-thirds over the next two years, cutting hundreds of jobs in the process. The plan also included an initial public offering of RBS’ Citizens Financial Group unit. The plan changed...


November 21, 2014 - Inside MBS & ABS

SG Americas’ Non-Agency MBS Trader Fired, Sanctioned by FINRA For Pre-Arranged Trading

The Financial Industry Regulatory Authority revealed recently that a non-agency MBS trader at SG Americas Securities was fired by the firm and sanctioned by FINRA for pre-arranged trading. The self-regulatory organization said that on multiple occasions from 2001 through 2013, Yimin Ge entered into an agreement with counterparties at other institutions to engage in pre-arranged trading. FINRA said such deals violate the Securities Exchange Act as well as FINRA’s rules. The pre-arranged trades involved...


November 21, 2014 - IMFnews

Fitch Dings Nationstar’s Servicing Ratings Due to Concerns About Financial Condition

Regarding Nationstar’s financial condition, Fitch previously referenced the financial condition of Fortress Investment Group, which owns 74 percent of the nonbank lender/servicer.


November 21, 2014 - IMFnews

CFPB Proposes Amendments to Mortgage Servicing Rules

Other changes include: providing flexibility for servicers to comply with certain force-placed insurance and periodic statement disclosure requirements.


November 21, 2014 - IMFnews

Risk-Based Pricing Continues: Lower FICO Score Borrowers Saw Bigger Hikes in G-Fees

The increase in g-fees last year made all three loan-purpose categories more profitable.


November 20, 2014 - IMFnews

Wilbur Ross Quits Ocwen’s Board – for Vice Chairmanship at Bank of Cyprus

Two years ago, Ross’ WL Ross & Co. sold its mortgage banking operation, Homeward Residential, to Ocwen for $750 million in cash and convertible preferred stock.


November 20, 2014 - Inside Mortgage Finance

Sen. Johnson Calls for End of Conservatorships, Dems Push Watt Hard on GSE Principal Reduction

The outgoing chairman of the Senate Banking, Housing and Urban Affairs Committee this week urged the head of the Federal Housing Finance Agency to look to a final resolution of Fannie Mae and Freddie Mac, while the progressives on the panel pressed the regulator and former Democrat congressman hard to approve principal reductions. “Everyone agrees that conservatorship cannot continue forever, so I hope my colleagues will keep working towards a more certain future for the housing market,” said Sen. Tim Johnson, D-SD, during a hearing with FHFA Director Mel Watt this week. But if “Congress cannot agree on a smooth, more certain path forward I urge you, Director Watt, to engage the Treasury Department in talks to end the conservatorship.” Watt did not address...


November 20, 2014 - Inside Mortgage Finance

CFPB Enforcement Actions Highlight What Mortgage Servicers Need to Look Out For

A careful examination of the big-ticket enforcement actions the Consumer Financial Protection Bureau has brought against leading mortgage servicers can help others in the space avoid the same fate and protect their bottom lines, according to top industry legal experts. During an Inside Mortgage Finance webinar earlier this week, Allyson Baker, a former CFPB attorney and partner at the Venable law firm in Washington, DC, discussed the importance of trends seen in a handful of servicing enforcement cases against Ocwen, SunTrust Bank and Flagstar Bank. “I think...


November 20, 2014 - Inside Mortgage Finance

FHA Mutual Mortgage Insurance Fund Capital Turns Positive, But No Change to Mortgage Insurance Premiums

The FHA Mutual Mortgage Insurance Fund has improved from a negative position to a positive $4.8 billion in FY 2014 after gaining nearly $6 billion in value over the last year, thanks to aggressive policy actions that led to improvements in key areas, according to an independent actuarial report sent to Congress this week. Overall, the fund showed a $21 billion improvement over the past two years due to changes the FHA implemented following the housing crisis, the report said. The changes led to improved underwriting standards for single-family mortgages, increased mortgage insurance premiums, stronger loss mitigation policies and higher recoveries, it noted. Aggressive policy actions also led...


November 20, 2014 - IMFnews

Short Takes: Stop Guessing on Lawsky Already / Share Price of Fannie and Freddie Common Soars / Foreclosures on the Rise / Essent Sells More Stock

A GSE bill? Since Congress and President Obama have such a strong track record of working together on legislation we know how that’s going to turn out…


November 20, 2014 - IMFnews

Fannie and Freddie Make it Official on R&W Relief but with Several ‘Exclusions’

In regard to misrepresentations, relief will not be offered if it can be proved that a borrower was misled by the originator. And, of course, any mortgage subject to fraud must be bought back.


November 20, 2014 - IMFnews

FHFA’s Watt: Fewer Than 100 Companies Affected by FHLB Membership Changes

Several weeks back, a FHFA official told IMFnews that just 18 members would be affected by the captive rule, mostly REITs.


November 20, 2014 - IMFnews

CFPB Increasingly Working with Other Law Enforcement ‘Partners’

Mortgage companies may not realize it, but the CFPB is partnering with the state attorneys general, the Department of Justice, and in some cases, the Department of Financial Services in New York.


November 19, 2014 - IMFnews

Short Takes: Any G-Fee News? No / Keeping an Eye on MSR Sales / Why Realtors Will Live Forever / California Home Sales Nothing Special / Jeb Will be Back, Hensarling At Least

After a servicing sale closes, the GSEs must monitor each transaction to make sure the transfer of receivables took place in a timely manner and more…


November 19, 2014 - IMFnews

CFPB Warns Mortgage Firms on How they Treat Borrowers with Disability Income

The new bulletin discusses standards and guidelines on verification of disability income, including those under the CFPB’s ability-to-repay rule.


November 19, 2014 - IMFnews

Senate Banking Chair Urges Watt and Treasury to End GSE Conservatorships

The two GSEs have been in conservatorship for six-plus years now, with no legislative solution to their future in sight.


November 19, 2014 - IMFnews

Morningstar: CMBS Market Notorious for ‘Rating Shopping’

The CMBS market is well known for rating shopping, where issuers will invite up to six CRAs to conduct a preliminary review of an initial asset pool.


November 18, 2014 - IMFnews

Lower FHA Premiums? Dream On…

In a statement, Rep. Hensarling decried last year’s $1.7 billion “taxpayer-funded bailout” of the FHA.


November 18, 2014 - IMFnews

Short Takes: Obama Won’t Give Up on Killing the GSEs / Redwood Sells Debt / More Ocwen Customer Complaints / Carrington Bolts ARMs / The Return of Mike Baldwin

Republicans have never been big fans of the GSEs and there’s plenty of Democrats who aren’t so sure about the government “guaranty” as well...


November 18, 2014 - IMFnews

FHFA: Extensive ‘Testing’ Underway at Common Securitization Platform

In 2015, the team at the GSE common securitization platform will focus on implementation of the remaining software components...


November 18, 2014 - IMFnews

Fannie Continues to Loosen Rules; 990 Days for a Foreclosure in New York

Fannie Mae recently loosened its credit standards on condominium loans. What's next?


November 17, 2014 - IMFnews

FHA’s Mutual Mortgage Insurance Fund in the Black by $4.8 Billion

The FHA’s annual independent actuarial review of the MMIF showed a capital reserve of 0.41 percent at Sept. 30, 2014.


November 17, 2014 - IMFnews

Short Takes: Former FHFA Chief Blasts Mortgage Industry / Who’s Behind the HIC? / More Relief From FHA / Ocwen’s Stock Recovers Slightly / Venable Hires Ex-Hensarling Staffer

So, which groups are behind the "housing-industrial complex"? DeMarco isn't naming names...


November 17, 2014 - IMFnews

FHFA’s Watt Testifies Before Senate Panel This Week; FHLB Membership a Key Topic?

The senate panel is expected to ask questions on guaranty fees and the common securitization platform as well.


November 14, 2014 - Inside The GSEs

Enterprise Endnotes

Ohio Court Sides With Freddie in Pre-Crisis Shareholder Lawsuit. An Ohio federal court late last week tossed out a shareholder class action lawsuit that accused Freddie Mac of lying about its exposure to subprime loans prior to the 2008 financial crisis. The suit, filed in 2008 by the Ohio Public Employees Retirement System, claimed that Freddie artificially inflated the value of its common stock by making false public financial statements that obscured its subprime exposure.OPERS claimed it lost as much as $27.2 million as a result of Freddie’s alleged cover-up of its subprime exposure.


Poll

What is it going to take to convince lenders to loosen the credit box (i.e., remove underwriting overlays)?

The recent rep and warranty changes announced by the Federal Housing Finance Agency should go a long way in protecting lenders from future buybacks and help expand mortgage credit.
There won’t be any significant elimination of underwriting overlays until the government stops seeking huge mortgage-related penalties and settlements from lenders.
There shouldn’t be any expansion of the mortgage credit box since looser underwriting is what caused the recent mortgage crisis.

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