www.lasvegasmtg.com Report: Are Credit Overlays another way of "Redlining"?
www.lasvegasmtg.com Report: Are Credit Overlays another way of "Redlining"? This is the argument that has been filed by National Community Reinvestment Coalition to FHA, The National Community Reinvestment Coalition has filed complaints against 22 lenders for having credit overlays that deny home loans to the poor and minorities. There are 17 other lenders that were not included in the complaint because they have agreed to meet with National Community Reinvestment Coalition.
It should be noted that the banks not named in this complaint are Bank Of America, JP Morgan Chase & Co, and Wells Fargo Bank. These banks have a lower credit score requirements for their institutions and higher requirements for their wholesale division. Wells Fargo Bank is part of the National Community Reinvestment Coalition Banker/Community Collaborative Counsel. Wells Fargo participation with the Council and not being named in the complaint is an interesting coincidence.
Redlining is the practice of arbitrarily denying or limiting financial services to specific neighborhoods, generally because its residents are people of color or are poor. The Government passed laws to eliminate this practice specifically The Fair Housing Act, Equal Credit Opportunity Act, and Community Reinvestment Act.
Credit Overlays are implemented by lenders to lower the risk of defaults that are shown to exist with lower credit scores. FHA minimum FICO scores is 580 and most lenders require a minimum of 620 or 640 minimum FICO scores. Even with the higher requirements by the lenders with credit overlays, there still will be hits to the rate based on FICO scores below 680 to 720 depending on the lenders overlay.
National Community Reinvestment Coalition argue that Credit Overlays are discriminatory against minorities and the poor. They argue that FHA loans are insured by the government so how can the lenders justify the overlays?
Lenders argue to lower the FICO score to FHA minimum of 580 the lenders will be incurring more costs and risks in underwriting the loans. FHA can also require the lender to buyback the loan when the borrower defaults if the review of the underwriting process has determined an error in any part of the application.
Redlining practices were wrong. Are Credit Overlays Redlining? I do not think so as it does not target certain geographical areas to deny access to financial resources. Poor Credit is not based on race or income level and can be caused from bad financial habits to circumstances beyond ones control.
Does it make sense to make FHA the new subprime loan as this will clearly be the case if we lower the FICO score to 580 to get a home loan? If Credit Overlays are going to be considered Redlining, then by what standards will be equitable to determine the ability to repay the loan? What do you think? Should we eliminate Credit Overlays? Will this increase the risk of more defaults on FHA loans? Will this create another sub prime product if enacted? I look forward to your opinions.