1. and the Regulatory Environment
August 2014
Impact of the CFPB
and the Regulatory Environment
on Credit Access
Debra Still
President/CEO

2. Source: MBA, Powered by AllRegs® Market Clarity®
Mortgage Credit Availability
MCAI
Index Baseline
June/14
115.8
Mar/12
100
Source: MBA, Powered by AllRegs® Market Clarity®

3. Expanded Historical Series: Mortgage Credit Availability Index
A Ways To Go Before “Normal”
Expanded Historical Series: Mortgage Credit Availability Index
Index Level By Month
June 2014 3

4. CFPB Rules/Other Regulation: Impact on Credit
Impact to Credit
Ability to Repay – QM Modest
HOEPA High-Cost Mortgage Rule None
Loan Officer Compensation Rule None
National Servicing Standards Modest
ECOA Appraisal Disclosure Rule None
Appraisals for High-Priced Mortgage Rule None
HUD Disparate Impact Rule Modest
Basel III Rule Modest
RESPA/TILA Integration Rule None
Coming Soon
Risk Retention/QRM ?
HMDA None
Loan Officer Anti-Steering Rule None
- Work = Costs to Consumers or lack of competition

5. If Not Regulation…Why is Credit Still Tight?
Operational Risk – Loan Manufacturing
“Guidelines” have become “rules”
Documentation is extraordinary
Lack of clarity of reps and warrants
GSE LQI
Fannie Mae “Zero Defect” QA program
FHA new QA/QC initiative
Financial Risk
Repurchases
Compensatory fees
Curtailment of debenture interest
Indemnifications
Enforcement
Reputation Risk
Headlines
FHA Compare Ratios