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.
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.”
At the time, industry attorneys were concerned the review sought by All American could take the Supreme Court beyond the analysis and determination sought in the Seila Law case...
Other matters on the government’s priority list: setting a commitment fee, resolution of the QM patch, and “any other similar changes that could impact the GSE footprint.”
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