How Lender-Mandated Credit Overlays Undermine the Mission of the GSEs
Imagine that you're a borrower with a credit score of 580 or worst yet no credit at all. You have what the Lenders call alternative credit (rent, utilities, cable & phone bill and etc.). You are employed with a qualified debt to income ratio and have saved a down payment of at least 3.5% and maybe some of your closing cost. On paper, you seem like a perfect candidate for an FHA loan. However, your lender denies your loan application because of your low FICO score or because you do not have a FICO score. Even though you have met the U.S. government's requirements for getting an FHA loan, your lender declines to approve your loan because of their credit overlays. This scenario is being played out every single day at all the major banks, credit unions and many mortgage banks. Who is in charge of the guidelines and parameters by which banks can lend? Are the additional credit requirements legal or discriminatory based on federal law? I believe that credit overlays are
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