Regulations

Browse articles from all of our Newsletters related to Regulations.

June 24, 2016 - IMFnews

What We’re Hearing: Mortgage Lenders to England: Thanks for Igniting Another Refi Boom / Servicers Cringe? Maybe Not / Brexit, Plunging Rates and the GSE ‘Hedging’ Issue / More on a Possible FHA MIP Cut / Capsilon Gets Investment from PE Firm

What does the Brexit vote for Fannie Mae and Freddie Mac? Hedging losses, maybe?


June 24, 2016 - IMFnews

Single-Security Transition Could Become Model for Figuring Out Future of GSE ‘Legacy’ MBS

In fact, the transition to a new GSE single security that’s scheduled to start in 2018 could become a test run of sorts for the even bigger changes ahead…


June 24, 2016 - Inside MBS & ABS

FDIC Revises Securitization Safe-Harbor Rule to Jibe With CFPB Mortgage Loan Servicing Requirements

The Federal Deposit Insurance Corp. this week revised its securitization safe-harbor rule to clarify loss mitigation standards for mortgage servicers to synchronize it with the similar requirements issued by the Consumer Financial Protection Bureau. The FDIC safe-harbor rule sets standards under which the agency will not attempt to capture assets of a failed bank that are transferred to qualifying securitizations. Under the previous rule, servicers of residential mortgages backing MBS that enjoy safe-harbor status were required to take loss mitigation action within 90 days after the loan becomes delinquent. In January 2013, the CFPB adopted...


June 24, 2016 - Inside MBS & ABS

New Concerns Arise About Nonbanks’ Ability To Meet Ginnie Mae MBS Servicing Advances

Ginnie Mae is once again getting anxious about the growing – and large – presence of nonbanks that service the agency’s MBS, fearing a liquidity crisis could erupt because some firms rely too heavily on “non-traditional and very sophisticated funding mechanisms.” In a statement issued to Inside MBS & ABS this week, Ginnie contrasted nonbanks to depositories “who traditionally were the primary issuers of Ginnie Mae MBS.” The agency added...[Includes one data table]


June 24, 2016 - Inside MBS & ABS

SEC to Re-Propose Long-Delayed Securitization Conflicts-of-Interest Rule Required by Dodd-Frank

The Securities and Exchange Commission will re-propose a rule addressing conflicts of interest regarding certain securitizations, according to SEC Chair Mary Jo White. The rule required by the Dodd-Frank Act was originally proposed by the SEC in 2011. “It’s proved to be much more complicated than our experts in the agency envisioned,” White said last week at a hearing by the Senate Committee on Banking, Housing and Urban Affairs. Section 621 of the DFA requires...


June 24, 2016 - Inside MBS & ABS

SFIG Publishes Standards to Help Non-Agency MBS Market Address TRID Issues, But CFPB Guidance Seen as Critical

The Structured Finance Industry Group late last week published a final draft of the standards for due diligence firms to use when testing loans for compliance with the Truth in Lending Act/Real Estate Settlement Procedures Act disclosure rule. “The underlying premise of this documentation is to establish a best practices approach to pre-securitization testing logic that will drive the due diligence conducted by third-party review firms,” SFIG said. The RMBS 3.0 TRID Compliance Review Scope documentation addresses...


June 24, 2016 - IMFnews

New Concerns Arise About Nonbanks’ Ability to Meet Ginnie MBS Servicing Advances

Ginnie Mae officials believe it is becoming increasingly important that nonbank mortgage servicers find new sources of capital...


June 23, 2016 - Inside Mortgage Finance

CFPB Seeks to Protect its Privileged Supervisory Records in Case Against Ocwen Loan Servicing

Earlier this month, the Consumer Financial Protection Bureau asked to intervene in a federal whistleblower case brought against Ocwen Loan Servicing in order to protect the confidentiality of its supervisory information. “The bureau seeks to intervene for the limited purpose of invoking the bank examination privilege and the bureau’s regulations to protect confidential and privileged bureau supervisory records and information related to the bureau’s supervision of Ocwen,” the CFPB said in its motion filed in U.S. District Court for the Eastern District of Texas, Sherman Division. Counsel for the relators in the case, Michael Fisher and Brian Bullock, and the defendants, Ocwen Loan Servicing and Ocwen Financial Corp., told...


June 23, 2016 - Inside Mortgage Finance

Sales of Ginnie Servicing Prove Difficult; Deals Are Getting Done, But Risk of FHA MIP Cut Overhangs the Market

The sale of residential mortgage servicing rights has been gaining steam the past few weeks – unless you happen to be in the market for Ginnie Mae product. In particular, there’s a growing concern about price discounts on Ginnie servicing rights, and a strong belief that the agency – including its president, Ted Tozer – is once again getting anxious about so many nonbanks being such large players in the market. Tozer is so concerned about the matter that the agency – with the help of the Mortgage Bankers Association – is hosting what’s been described as a “liquidity summit” in Washington, DC, with several stakeholders and regulators, including officials from the Federal Reserve and U.S. Treasury. The summit, closed to the media, is scheduled for June 24. Ginnie issued...


June 23, 2016 - Inside Mortgage Finance

Subservicing Keeps Growing as Regulatory Headaches Force MSR Owners to Cut Costs and Outsource

Subservicing vendors continued to increase their contract totals in the first quarter as owners of mortgage servicing rights moved more of their business to these specialists to counter regulatory burdens that show few signs of abating. According to exclusive survey figures compiled by Inside Mortgage Finance, $1.625 trillion of home mortgages were being handled by subservicers at March 31, a 5.5 percent sequential increase and a 19.5 percent gain year-over-year. Subservicing firms – a business mostly dominated by nonbanks with one key exception – now process...[Includes one data table]


June 23, 2016 - Inside Mortgage Finance

Is the TRID Good-Faith Compliance Phase Over? Industry, Regulator, Attorney Accounts Are Split

Late last week, news broke of a conversation from a closed session at the American Bankers Association conference in San Diego that the “sensitive” approach by regulators to respect lenders’ good-faith efforts to comply with the Consumer Financial Protection Bureau’s integrated disclosure rule may have come to an end. According to one well-placed source, the CFPB and the other regulators – the Federal Reserve, the Federal Deposit Insurance Corp. and the Office of the Comptroller of the Currency – have decided that they will start examining banks for technical compliance with TRID, begin requiring restitution to affected borrowers, and start citing banks that are in non-compliance. “Apparently, the message is...


June 23, 2016 - IMFnews

Ginnie Mae Hosts ‘Liquidity Summit’ on Friday; A Concern That the Megabanks Have Split for Good?

How big of a deal in this liquidity summit? Well, officials from the Federal Reserve and Treasury Department will be there...


June 23, 2016 - IMFnews

Ocwen to Settle with DOJ for $30 Million in FCA Lawsuits Involving HAMP and FHA

In trading Thursday, Ocwen’s share price was up almost 8.0 percent on the day to $1.69 a share.


June 23, 2016 - IMFnews

CFPB Singles Out Loan Servicers for Tech Failures. Are Fines Coming?

CFPB examiners found problems with loan modification acknowledgement notices, including sending them too late and having incorrect information or deceptive statements…


June 22, 2016 - IMFnews

Short Takes: FHA Ready to Cut the MIP? / 100 Guests at Ginnie Liquidity Summit / In Demand: Mortgage Underwriters / Citadel Employee Count at 160 and Growing / Freddie Keeps Selling NPLs

Roughly 100 guests were invited to the Ginnie Mae "liquidity summit," including regulators from the Federal Reserve.


June 22, 2016 - IMFnews

25 Trade and Community Groups Tell FHFA Chief Mel Watt: Kill LLPAs Now

The mortgage industry and others want LLPAs eliminated now...


June 22, 2016 - IMFnews

Federal Regulators Plead for Housing Finance Reform Legislation, Note They are ‘Approaching the Limits of their Ability to Enact Reform’

Financial regulators tell Congress: Do something now on GSE reform before it's too late...


June 20, 2016 - IMFnews

Short Takes: Up and Down Mortgage Mt. Everest / Going Online with IO Ads / Overture’s Tech Update / DOJ Abandons Case Against Countrywide Founder Mozilo

Social Finance (SoFi) and Guaranteed Rate are among the lenders advertising their interest-only offerings online…


June 17, 2016 - Inside FHA/VA Lending

Around the Industry

FHA Revises TOTAL Mortgage Scorecard. Effective on June 11, 2016, the FHA’s TOTAL Mortgage Scorecard no longer returns either upfront or annual mortgage insurance premium factors to an automated underwriting system. The FHA directs lenders to consult Appendix I of its Single Family Housing Policy handbook for applicable MIP factors. AUS vendors have been notified of the change and have adjusted their systems accordingly. HUD, First Citizens Bank Settle Fair Lending Complaint. A South Carolina bank has agreed to correct its lending practices and allocate funding to resolve allegations that it denied more loans to minorities compared to similarly-situated white loan applicants. The settlement agreement stemmed from a complaint filed by the Department of Housing and Urban Development against First Citizens Bank and Trust Co. in 2011 after an analysis of ...


June 17, 2016 - Inside FHA/VA Lending

CA Realtors Seek Rule to Prohibit PACE Lien Seniority over FHA Lien

The California Association of Realtors renewed its push for rules addressing the proliferation of FHA-insured mortgages that have Property Assessed Clean Energy super liens. In a recent letter to Office of Management and Budget Director Shaun Donovan, the CAR requested that both FHA and the Department of Housing and Urban Development adopt policy that is consistent with the Federal Housing Finance Agency’s existing policy on PACE liens. Specifically, such a policy would prohibit the use of PACE encumbrances with a “super lien” priority over mortgage financing. The group also urged HUD to issue guidelines directing FHA lenders and servicers not to place PACE liens above any mortgage insured by FHA. The CAR expressed concern about how PACE liens might affect the FHA Mutual Mortgage Insurance Fund, which is currently recovering from years of losses. “If the ..


June 17, 2016 - Inside FHA/VA Lending

VA Servicer Reminders: Conveyance Guide, POC List, Compromise Sale

The Department of Veterans Affairs Home Loan Guaranty staff is reminding VA servicers of new title requirements taking effect this week for conveying properties to the VA. Under VA regulations, a conveyance or transfer of real property to the department is acceptable if the holders of the VA-guaranteed loan provide covenants or warranties against the acts of the holder and/or their agents. In addition, conveyances would be acceptable to the VA if it vests or entitles the agency to such title as is. In addition, the VA would take possession of collateral as long as it is acceptable to prudent lenders, informed buyers, title companies and attorneys in the community in which the property is located. However, the VA’s determination of clear and marketable title rests on state statutory requirements, the agency noted in its guidance. The VA is providing servicers a revised state-by-state list of ...


June 17, 2016 - Inside FHA/VA Lending

HOAs Required to Disclose VA, FHA Certification of Condo Projects

A new California law requiring condominium homeowner associations to disclose to their members whether the VA or the FHA has certified their buildings will soon take effect.Starting July 1, 2016, California HOAs will have to disclose in their annual budget report whether or not their condominium projects have been approved for VA or FHA financing. Gov. Jerry Brown, D, signed Assembly Bill 596 into law in August last year to encourage more veterans and first-time homebuyers to purchase condominiums and take advantage of the benefits of government-backed home financing. In signing the measure into law, Brown expressed hopes that condominium HOAs will step up their certification or recertification process. Assemblyman Tom Daly, D-Anaheim, author of the bill, estimates there are 28,000 condo projects in the Golden State, and only a third are FHA-certified. There are far fewer projects that are ...


June 17, 2016 - Inside FHA/VA Lending

Potential FHA Rate Cut Possible, Private MIs Have Nothing to Fear

An FHA price reduction remains a possibility but its impact is likely to be limited, according to analysts at Keefe, Bruyette & Woods. While some industry observers might think another mortgage insurance premium cut is inevitable, there is no broad pressure from any group or coalition that would compel FHA to do so, said KBW analysts Bose George and Chas Tyson, both panelists at KBW’s Mortgage Finance Conference recently. Given last year’s 50-basis-point cut, the FHA’s ability to cut rates meaningfully is somewhat limited, they said. The FHA annual MIP is currently 80 to/or 85 bps, down from the pre-reduction premium of 130 to/or 135 bps and higher compared to the average annual premium of 50 to/or 55 bps before the financial crisis. If FHA decides to reduce the premium again, George and Tyson believe the floor will likely be at the pre-crisis premium level, which would suggest a ...


June 17, 2016 - Inside FHA/VA Lending

FHA Production on a Positive Trend Despite Falling Endorsement Levels

FHA single-family forward endorsements fell by 8.0 percent in the first quarter of 2016 from the prior quarter, suggesting a continued slowing in endorsement in the latter part of 2015 and early 2016 compared to earlier quarters, according to the FHA’s latest quarterly report to Congress on the state of the Mutual Mortgage Insurance Fund. Overall though, the FHA MMIF report as well as FHA monthly production reports for March and April continued to show the very positive trends – rising volume, lower delinquencies and outstanding credit quality – that have been occurring in the FHA program since 2009. Endorsement volume for purchase and refinance loans was down to $53.5 billion during the first three months of 2016 from $58.1 billion in the fourth quarter of 2015, the MMI Fund report showed. Last year, forward endorsements soared in the second quarter and reached a record high in the ...


June 17, 2016 - Inside FHA/VA Lending

Maximum Civil Penalties for HUD, FHA Violations Set to Increase

FHA lenders will face stiffer maximum monetary penalties later this year for various violations of agency rules and regulations. The higher monetary penalties are the result of legislation signed into law late last year requiring federal agencies to adjust the current maximum penalty amounts for inflation in order to maintain their deterrent effect. Specifically, the Federal Civil Penalties Inflation Adjustment Act of 2015 (2015 Act) requires federal agencies to adjust the level of civil monetary penalties with an initial “catch-up” adjustment through an interim final rule and subsequent annual adjustments for inflation. The interim final rules with the initial penalty adjustments must be published by July 1, 2016. The new penalty levels must take effect no later than Aug. 1, 2016. Additionally, agencies are required to make annual inflation adjustments, starting Jan. 15, 2017, and for each year going forward. The adjustments will ...


June 17, 2016 - IMFnews

What We’re Hearing: Worrying About Nonbanks – Again / Banks and the GSEs: The Love Affair is Over / Keep it Under $5 Billion So the FHFA Won’t See It / GSE Discounts are Back? / Does the FHFA IG Have Enough To Do? / If You Give a Child a Credit Card…

Late this week we were hearing reports about one mortgage cooperative that was trying to strike a deal with one of the GSEs regarding pricing breaks for its members...


June 17, 2016 - IMFnews

Time’s Up. The CFPB’s ‘Good Faith’ Period on TRID Compliance is Over!

The days of “kinder” and “gentler” TRID enforcement are a thing of the past…


June 17, 2016 - Inside MBS & ABS

Commercial MBS Issuers Still Unsure of How to Comply with Risk-Retention Requirements that Take Effect in December

With time ticking toward a Dec. 24 compliance date, issuers of commercial MBS continue to try to develop structures that will meet risk-retention requirements. Richard Jones, a partner at the Dechert law firm, warned that the industry is “in trouble.” In an analysis published this month, he wrote, “We as an industry don’t have a scalable solution to the problem. We … do not know what this will cost, who will pay for it, and to what extent this is an existential risk to commercial real estate capital formation as it has been conducted for the past 25 years.” He noted...


June 17, 2016 - IMFnews

Lenders Face Higher Maximum Penalties for Mortgage ‘Violations’

The Consumer Financial Protection Bureau this week issued an interim final rule showing an 8.5 percent increase in the maximum civil penalties it can obtain for various consumer protection violations…


June 16, 2016 - Inside Mortgage Finance

Appraisers See ‘Existential Threat’ to Industry Regulation With Broad Exemption for Federally-Related Transactions

Two appraiser trade groups raised concerns this week that federal banking regulators are re-interpreting longstanding policy to exempt most of the mortgage market from appraisal rules. The American Society of Appraisers and the National Association of Independent Fee Appraisers published a white paper and wrote to leaders in Congress detailing positions taken by federal regulators regarding the application of appraisal standards included in the Financial Institutions Reform, Recovery and Enforcement Act. Federal regulators are...


June 16, 2016 - Inside Mortgage Finance

Maximum Penalties for Violations of Mortgage-Related Laws, Regulations Set for Significant Increases Later this Year

Mortgage lenders soon will be facing higher civil monetary penalties that may be imposed by federal agencies for violations of various lending, servicing and consumer financial protection laws and regulations, warned industry attorneys. As part of the budget bill signed into law last year, the Federal Civil Penalties Inflation Adjustment Act (FCPIAA) requires federal agencies to adjust the civil penalty amounts they charge for inflation by July 1, 2016. This will be followed be regular adjustments by January 15 of every year. The adjustments must be...


June 16, 2016 - Inside Mortgage Finance

Problems With TRID Continue to Mount, Industry Presses to Adapt While Awaiting New Rulemaking

The Consumer Financial Protection Bureau plans to develop another rule to resolve some of the mortgage industry’s problems with the CFPB’s integrated disclosure rule may provide some psychological relief for lenders. But it’s certainly not solving any of the problems they are struggling with right now, problems that continue to emerge as the months since implementation roll on. Among the host of concerns that have sprung up related to the Truth in Lending Act/Real Estate Settlement Procedures Act Integrated Disclosure Rule – TRID – is the raft of issues having to do with settlement agents. Delivering a presentation at the American Bankers Association’s regulatory compliance conference this week, Richard Horn, a former CFPB official, said...


June 16, 2016 - Inside Mortgage Finance

Lenders, Don’t Get Your Hopes Up Too High for TRID 2.0, Industry Pros Advise

Mortgage lending industry representatives were told to keep their expectations in check when it comes to the forthcoming TRID integrated-disclosure rulemaking from the Consumer Financial Protection Bureau, which is expected sometime this summer, perhaps as early as late July. “Everybody in the industry cheered when the bureau announced this,” attorney Richard Horn, the former CFPB official who led the development of the TRID rule, said this week during a panel discussion at the American Bankers Association’s regulatory compliance conference in San Diego. “I think...


June 16, 2016 - IMFnews

Short Takes: Hillary, Donald, Fannie and Freddie? / NAHB Prefers ‘Ranieri-Zandi’ Plan / Spend It. Otherwise Uncle Sam Gets That Money! / Fannie Eventually Will Make a Killing in RE / Former New Century Chief Lands at Carrington

Eventually, Fannie Mae will sell its historic HQ site at 3900 Wisconsin Avenue in Washington, DC, and making a killing on the sale...


June 16, 2016 - IMFnews

FHFA Chief Rebuts IG Claim Regarding Not Controlling Costs on New Fannie Mae HQ

FHFA chief Mel Watt also points out that the sale of Fannie’s existing properties will result “in substantial additional financial benefits.”


June 16, 2016 - IMFnews

CFPB Expected to Codify ‘Informal’ TRID Guidance

The CFPB will take all of the content and commentary it has provided informally during webinars and at industry events, reconstituting it into some type of formal, definitive, and authoritative guidance.


June 15, 2016 - IMFnews

Short Takes: Mortgage Trade Group v. Mortgage Trade Group? / MBA’s Stevens Reacts / Quicken Selling Loans to Berkshire’s Mortgage Unit / Why Moody’s Can't Rate JPM’s LO System / Fannie Hires New Chief Audit Executive

MBA President Dave Stevens told IMFnews: “We respect the work of Glen [Corso, CMLA director] and his organization greatly...."


June 13, 2016 - Inside the CFPB

News in Brief

Compass Point predicts that CFPB will lose its dispute with PHH. The CFPB is hosting an eRegulation webinar. HUD and First Citizens Bank (SC) resolve a fair lending complaint spurred by HMDA data. And CFPB staff exit for SunTrust and JH Capital Group.


June 14, 2016 - IMFnews

CFPB TRID Exams Coming This Month

Two industry sources confirmed this week that the Consumer Financial Protection Bureau will, indeed, begin examining for compliance with the integrated disclosure rule known as TRID this month.


June 13, 2016 - Inside the CFPB

CFPB Issues Restrictive Rule to Crack Down on Payday Lending

The CFPB has issued its long-awaited payday lending proposed rule, in essence a highly restrictive ability-to-repay rule for small-dollar lending. Under the proposed full-payment test, lenders would be required to determine whether the borrower can afford the full amount of each payment when it’s due and still meet basic living expenses and major financial obligations.


June 13, 2016 - Inside the CFPB

FTC Details Actions Taken Against Forensic Audit Scams

In its annual report to the CFPB, the Federal Trade Commission detailed the enforcement work it did last year in three cases dealing with mortgage assistance relief services, several of which involved alleged forensic audit scams.


June 13, 2016 - Inside the CFPB

CFPB Sues Payment Processor Intercept Corp. Over Withdrawals

The CFPB filed suit against Intercept Corp., a third-party payment processor located in Fargo, ND, and two of its executives for allegedly enabling unauthorized and other illegal withdrawals from consumer accounts by their clients. The CFPB alleges that Intercept and the executives violated the Dodd-Frank Act’s prohibition against unfair acts and practices by processing payments for clients without adequately investigating, monitoring or responding to red flags that indicated some clients were breaking the law or deceiving customers.


June 13, 2016 - Inside the CFPB

Republicans Target CFPB On Two Fronts, Waters Defends

House Financial Services Committee Chairman Jeb Hensarling, R-TX, detailed in a speech a proposal that House Republicans have been working on that would replace the Dodd-Frank Act, including some important changes that would scale back the powers of the CFPB. The bill would shift the agency’s mission to include both consumer protection and maintaining competitive markets, with a cost-benefit analysis of rules performed by an Office of Economic Analysis. Also, it would replace the current single director with a bipartisan, five-member commission which would be subject to congressional oversight and appropriations.


June 13, 2016 - Inside the CFPB

Rep. Hensarling, Sen. Paul Push QM Safe-Harbor Legislation

Rep. Jeb Hensarling, R-TX, chairman of the House Financial Services Committee, rolled out some of the details of a Republican proposal to replace the Dodd-Frank Act, the Financial CHOICE (Creating Hope and Opportunity for Investors, Consumers and Entrepreneurs) Act. The proposal includes the text of a measure already passed by the House, which would provide a QM safe harbor for any mortgage that has been held in portfolio by a depository institution since origination.


June 13, 2016 - Inside the CFPB

TRID May Help Extend the Push Toward Paperless Mortgage: Survey

The 11th annual Xerox Path to Paperless Survey finds what appears to be an accelerated pace toward making the paperless mortgage a reality. And the CFPB’s integrated disclosure rule known as TRID is apparently helping.


June 13, 2016 - Inside the CFPB

Fannie Mae Clarifies Expectations Re: TRID Error Self-Reporting

Fannie Mae recently provided sellers with a little more guidance on its expectations related to lender self-reporting of errors in complying with the CFPB’s new disclosure regime under the Truth in Lending Act and the Real Estate Settlement Procedures Act.


June 13, 2016 - Inside the CFPB

Still Some Trading in TRID Defects, But Jumbo Market Looking Up

According to investors in scratch-and-dent TRID mortgages and traders who play in the space, auctions of mortgages with errors (of all sorts) have continued apace ever since the CFPB announcement on TRID 2.0 rulemaking in early May and show little sign of slowing down. At the same time, the TRID mortgage disclosure rule appears to be less of an obstacle for the jumbo mortgage-backed securities market these days as JPMorgan Chase prepares a deal that will include residential loans subject to the rule.


June 13, 2016 - Inside the CFPB

NAR Urges Bureau to Clarify that Lenders Can Share TRID CDs

In a letter sent to CFPB Director Richard Cordray, the National Association of Realtors asked the agency to clarify that mortgage originators can share the closing disclosure (CD) form with third parties “if the lender receives a consent form from the consumer.” The trade group noted that, before the TRID rule was implemented, real estate agents aided their clients by answering questions about the HUD-1 and by reviewing terms agreed to in the sales contract, such as concessions, escrows, commissions and shares of prorated taxes.


June 13, 2016 - IMFnews

Analyst Predict CFPB Will Lose Dispute with PHH and Cause Leadership Shift

When it comes to CFPB enforcement, analysts at Compass Point Research & Trading said in a recent client note that they expect little shift from the bureau’s current agenda.


June 10, 2016 - Inside The GSEs

Sen. Warren Pushes for Comment On FHFA Super-Lien Opposition

Sen. Elizabeth Warren, D-MA, is urging the Federal Housing Finance Agency to solicit public comments on FHFA’s policy regarding super-liens imposed by homeowner associations on loans in foreclosure. The FHFA has said it is obligated to protect the rights of Fannie Mae and Freddie Mac and will aggressively do so. Super-lien laws are currently in 22 states and the District of Columbia. They allow homeowner associations that are owed fees to take priority over ...


Poll

What is the very best source of new mortgage customers for your lending shop? (Choose one only.)

Leads provided to me by employer

13%

Paid internet/website leads

9%

Real estate agents/Realtors

31%

Homebuilders

6%

Our existing customer base/our servicing customers

19%

My own personal sales "leads" database

13%

Other

9%

Housing Pulse