CRA, Call Report, Non-QM U/W Tools; ROAD to Housing Bill Viewed; Immigration and Credit Reminder

By: Rob Chrisman

Ever heard someone say something that was blatantly misleading? On July 16, at 2PM ET, you can race to buy one of Olive Garden’s 10,000 “Never Ending Pasta Passes.” But it does end, after 13 weeks. Yup, for $100 you can economically gain a lot of weight, since it’s in our DNA to do so. Speaking of DNA, do you really think that it is in the DNA of retail companies like Guild, American Pacific, Movement, CrossCountry, etc., to stop expanding? Nope, they’ll keep going, and if you want to know the mindset of a lender that doubled its purchase business from last year, listen to the interview with Zillow Home Loans’ Eric Wilson on how the company is guiding buyers, helping them move from pre-approval through closing with support from centralized processing, underwriting, and closing teams (at the 4:45 minute mark) all the while sending other lenders leads. Lenders of all sizes obviously know that compliance is important, and in Brian Levy's latest Mortgage Musings he covers the Consumer Finance Protection Bureau's new Enforcement Principles which create no enforceable rights, no safe harbor, and could vanish with a website edit. Tomorrow on L1’s Mortgage Matters, Mitchell Sandler's Ari Karen discusses the mortgage litigation space, potential updates to RESPA, storm clouds with AI from a legal perspective. (Today’s podcast can be found here… this week’s ‘casts are sponsored by Zillow Home Loans, Zillow’s in-house mortgage lender. By integrating Zillow’s real estate platform with financing, Zillow Home Loans helps buyers move from dreaming about a home to holding the keys, and loan officers focus on guiding buyers with care and confidence. Today’s has an Interview with MCT’s Leslie Winick on the evolving role of a Chief Strategy Officer, exploring how technology companies can stand out in the AI era through customer-centric strategy, operational excellence, effective change management, and goal alignment.)

Lender and Broker Software, Products, and Services

40 percent of the nation's Top 25 IMBs are now partnered with OptiFunder, representing more than 100,000 monthly loans funded through the Genesis platform and driving continued growth across the OptiFunder ecosystem. As adoption accelerates, warehouse lenders, originators, investors, and service providers are benefiting from this connected ecosystem, powered by a growing network of integrations through the Genesis and Greyhound platforms. The result is greater automation, enhanced security, and more efficient collaboration throughout the mortgage lifecycle. With new IMBs, warehouse lenders, and technology partners joining the ecosystem regularly, the value of connectivity continues to increase. Mortgage lenders are progressively adopting connected technologies that reduce operational friction, improve efficiency, and deliver greater transparency across the lending process. Talk to an OptiFunder team member to streamline operations, strengthen partner relationships, and leverage one of the fastest-growing mortgage networks in the industry.

If you’re doing non-QM loans, handling the calculations for deposit-based income is a time-consuming process that can be a breeding ground for errors. Join Cotality on July 15 at 11 a.m. PT for a 45-minute webinar around Using Cash Flow Analysis to support non-QM underwriting. During this session, we will highlight how new tools can help you automate many steps of the deposit-based income process, saving you hours of processing time and greatly reducing the chance of income calculation errors. Register today and see how you can take the hassle out of deposit-based income calculations.

“Ace Your Back-to-School Pipeline with Pennymac TPO’s non-QM Suite! The bell is ringing on prime buying season. From self-employed parents eyeing top districts to investors targeting campus housing, don't let traditional guidelines cost you a closed deal. Expand your reach with Pennymac TPO’s comprehensive non-QM suite. From DSCR loans that qualify based on property cash flow to alternative documentation for self-employed entrepreneurs, we give you the tools to close underserved files. Deliver tailored solutions this back-to-school season with Pennymac TPO! Contact your Pennymac TPO Account Executive or become a partner today to get started. (Equal Housing Lender, NMLS #35953)”

Truework, a Checkr Company is the unified income, employment, and asset verification platform built for mortgage lenders, replacing slow, manual processes with fast and automated reports pulled directly from payroll providers and other authoritative data sources. Lenders see up to 50 percent cost savings on verifications, with faster turn times and higher accuracy. Trusted by 4 of the top 5 lenders in the US, Truework delivers verification results your team can rely on. Learn more.

August means it’s time for the California MBA’s 2026 Western Secondary Market Conference. As a sponsor of this year’s event, Western Alliance Bank’s Specialized Mortgage Services Group looks forward to connecting with industry colleagues August 10-12 at Terranea Resort in Palos Verdes, California. Along with colleagues at Western Alliance Bank’s wholly owned subsidiary, AmeriHome Mortgage, the team invites attendees to join them at the All-Attendee Party on Monday, Aug. 10, from 6-9 p.m. on the 4th Floor Terrace. With more than 16 years of mortgage banking experience, Western Alliance’s Specialized Mortgage Services Group delivers tailored solutions including mortgage warehouse lending, MSR financing, note financing, customized treasury management, corporate credit cards, fraud protection and a whole loan trading desk focused on purchasing scratch-and-dent loans (send bid requests to SnD@westernalliancebank.com). To learn how Western Alliance can help drive profitability and support your goals, meet with the Western Alliance team at the conference. Western Alliance Bank, Member FDIC.

The CRA calendar runs backward. By the time the next bank exam shows up, the loans you needed were on someone else's tape three quarters ago. Banks scrambling for LMI in November pay November prices. Banks sourcing in July are paying July prices. The math is unsentimental. Having a systematic approach and buying throughout the year means you don't need to overpay during crunch time. GATHER™, Black Lake's all-digital CRA marketplace, tags every loan with FFIEC-grade geo data, matches it to your assessment areas, and routes diligence, bid, and settlement through one workflow. Your CRA officer gets an auditable trail. Your treasurer gets a price that wasn't set by panic. No cost for selling CRA eligible loans on the platform. Q4 is closer than it looks. Start now, not later. Reach out to Wayne Brown to learn how GATHER™ can help you hit your 2026 CRA goals.

The Q2 Mortgage Call Report deadline is August 14. Like many things in mortgage, the accuracy of MCR filings relies heavily on good data hygiene. One coding error or reconciliation gap could trigger state regulator follow-up you don't need. Before submitting, lenders need to reconcile loan activity, financial data, and operational information for each state they hold a license, across multiple NMLS schedules. Firstline Compliance helps institutions review and prepare those filings before submission, removing the plaque and helping your team file with confidence and a bright white smile! With the deadline approaching, now's the time to get ahead of it. Contact Ashley Bradford at 469-717-4232 to schedule your next cleaning!

Meet CoreSync: the end of digital speed bumps in private-label subservicing. LoanCare’s latest innovation eliminates one of industry's biggest pain points: the disconnect between your branded customer experience and the servicing experience. Built on LoanCare’s next-gen technology integration, CoreSync embeds mortgage servicing capabilities directly into your existing website, app, and branch platforms, so homeowners never have to leave your environment to manage their loan. The result is a seamless, fully branded experience that keeps your customers connected to you, the institution they already know and trust. Download the Tech Brief and discover how CoreSync is redefining private-label subservicing.

The Chrisman Marketplace is a centralized hub for vendors and service providers across the industry to be viewed by lenders in a very cost-effective manner. We’re adding new providers daily, so check back often to see what’s new. To reserve your place or learn more, contact us at info@chrismancommentary.com.

Borrowers, Immigration, Credit, and the Administration

No one is expecting loan officers to become immigration officials, right?. The Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, and the National Credit Union Administration issued guidance to remind supervised financial institutions of their existing obligations with respect to credit risk management, particularly as it relates to borrowers who are not legally authorized to work in the United States.

“Lending to individuals who are not legally authorized to work in the United States may present elevated credit risk because a borrower’s ability to generate income, maintain employment, and remain financially stable may be subject to greater uncertainty. Among other things, the guidance advises financial institutions to identify, measure, monitor, and control these risks through safe and sound underwriting practices that assess a borrower’s willingness and capacity to repay according to the terms of the credit obligation.

“The guidance also advises financial institutions to carefully consider the June 8, 2026, “Statement on Ability to Repay and Immigration Status,” issued by the Consumer Financial Protection Bureau, reminding creditors of their obligations under the Truth in Lending Act as implemented by Regulation Z, and the Equal Credit Opportunity Act, as implemented by Regulation B, as they relate to non-work authorized borrowers.

“The agencies issued the guidance in accordance with Executive Order 14406, “Restoring Integrity to America’s Financial System,” to address risks to the financial system posed by the extension of credit or financial services to the inadmissible and removable population.”

ROAD to Housing Bill

The bill which was enacted Friday night through not being vetoed by President Trump… what are some of its aspects? It exempts certain housing-related activities from the environmental review process, including certain construction, improvement, or rehabilitation of residential buildings; excludes veterans' disability benefits from being considered as income for purposes of determining eligibility for the Veterans Affairs Supportive Housing (VASH) program; and eliminates the requirement that manufactured homes must be constructed with a permanent chassis; and

Allen Matkins wrote up a thorough piece on what the Bill means, if anything, for large institutional investors.

The bill, though politically monumental (both chambers approved it overwhelmingly) doesn’t do one big thing. Instead, it does a lot of little things. Individually, none of the bill’s 56 regulatory tweaks, pilot programs and low-cost loans and grants are likely to move the needle on the nation’s housing affordability woes, nor on California’s specifically.

Capital Markets

U.S. Treasuries and Agency MBS opened the week gaining in yield due to rising oil prices and renewed geopolitical tensions surrounding the Strait of Hormuz. Treasury yields and Fed rate-hike expectations have climbed recently on renewed concerns that higher oil prices will reignite inflation. In the absence of economic data, markets remain focused on Iran-related developments, while rising/firmer expectations for additional Fed rate hikes continue to pressure the front end of the yield curve; short-term Treasury yields hit new 2026 highs yesterday and longer-term yields lifted closer to their May peaks.

Yet financial markets have remained surprisingly resilient. Oil prices have risen only modestly, suggesting investors believe any Gulf shipping disruption will ultimately be temporary, while equities remain near record highs and Treasury yields have moved higher only gradually. Attention now shifts to Fed Chair Warsh's first semiannual congressional testimony, which will help shape expectations for the July 29 FOMC meeting (and beyond).

With markets showing limited signs of stress, there is little immediate pressure for policymakers to de-escalate the conflict, although a prolonged closure of the Strait would eventually tighten global oil supplies and increase inflation risks. Investors remain alert to the possibility that a less transparent Fed under Warsh could increase meeting-to-meeting policy uncertainty, making incoming inflation data and Fed communication more influential in driving short-end Treasury yields.

Agency MBS underperformed again last week as higher Treasury yields weighed on returns, though Fannie Mae 15- and 20-year securities held up better than other loan types amid historically subdued interest-rate volatility and improving mortgage convexity. Within the coupon stack, higher-coupon securities continued to outperform, while relative valuations suggest Agency MBS remain attractive versus investment-grade corporates but mixed relative to Treasuries, with Fannie Mae 30-year securities appearing relatively rich and 15-year pools offering better value. Select specified pools (particularly newer vintages with favorable loan characteristics and mid-stack coupons) continue to stand out as opportunities for investors seeking relative value.

Today’s economic calendar kicked off with June’s NFIB Small Business Optimism Index, rebounding to its highest level in four months. We’ve also received the all-important June CPI, -.4 percent versus expectations of a 0.1 percent decline and prior reading of 0.5 percent, +3.5 percent Y-o-Y, and Core CPI (unchanged versus expectations of a 0.2 percent increase and prior reading of 0.2 percent, +2.6 percent Y-o-Y). The report is even more pivotal as investors assess whether geopolitical energy risks will overshadow what would have (should have?) otherwise be an in-line inflation reading. Core services inflation is expected to temper on lower travel costs as well as primary shelter.

Later today brings Redbook same store sales, and Fed remarks from Vice Chair for Supervision Barr, Chicago President Goolsbee, and Governors Cook and Bowman. After the inflation data Agency MBS prices are better than Monday’s close by about .250, the 2-year is yielding 4.17, and the 10-year is yielding 4.53 after closing yesterday at 4.61 percent.