The $11.6 billion deal resolved Fannie's long-standing claims that BofA sold the GSE defective mortgages and mishandled various loans it serviced for Fannie between 2000 and 2008.
The CFPB, HUD and the Department of Justice have all gone on record asserting that disparate impact claims are viable under the Fair Housing Act and the Equal Credit Opportunity Act.
With Fannie lowering its LTV maximum it will reduce the pool of eligible GSE borrowers and likely shift those loans over to FHA, which means private mortgage insurance firms will lose business.
Cerberus Capital is contemplating purchasing additional mortgage banking firms. Meanwhile, the CFPB doesn't like what it sees in the servicing space when it comes to customer service.
Currently, FHA requires a waiting period of two years in bankruptcy cases and three years after a foreclosure or short sale before a borrower can apply for an FHA loan.