We are requesting that this rule which defines a differentiation between loan originators as either mortgage broker’s or creditor’s has the unintended consequence of limiting the choices available to the consumer and allows creditors to create a monopoly of the mortgage market. Creditors impose the lending restrictions of their stockholders. By being risk averse, creditors are limiting loan product options provided to the underserved mortgage consumer and are unwilling to provide instructions to this group on how to improve their credit file. Removing the limitation on income as imposed exclusively to mortgage broker’s who are in market, local providers of lending services, will provide better options to all, and specifically to those who are underserved in our community.
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