Among the proposed changes: A residential loan made to a high-income individual residing in low- and moderate-income neighborhoods would no longer qualify for CRA credit.
What’s so interesting about the Sterling disclosure is that it comes from a bank. For the most part, depositories have shied away from non-QMs unless it’s jumbo product made to wealthy individuals…
The forms of documentation allowed through Sterling's Advantage Loan program are more vulnerable to manipulation and misrepresentation than traditional documentation programs, according to Fitch.
The crux of the matter: “The agencies are aware that the use of certain alternative data may present no greater risks than data traditionally used in the credit evaluation process.”
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