To All State Member Banks, Bank Holding Companies and
Others Concerned in the Second Federal Reserve District:
The federal financial regulatory agencies have issued for comment proposed guidance on residential mortgage products that allow borrowers to defer repayment of principal and sometimes interest.
These nontraditional mortgage products include "interest-only" mortgage loans where a borrower pays no principal for the first few years of the loan and "payment option" adjustable-rate mortgages where a borrower has flexible payment options, including the potential for negative amortization.
Institutions are also increasingly combining these mortgages with other practices, such as making simultaneous second-lien mortgages and allowing reduced documentation in evaluating the applicant's creditworthiness.
While innovations in mortgage lending can benefit some consumers, the agencies are concerned that these practices can present unique risks that institutions must appropriately manage.
The agencies are also concerned that these products and practices are being offered to a wider spectrum of borrowers, including subprime borrowers and others who may not otherwise qualify for more traditional mortgage loans or who may not fully understand the associated risks of nontraditional mortgages.
Comment is requested on all aspects of the guidance, particularly on the section regarding comprehensive debt service qualification standards. Comments are due 60 days after publication in the Federal Register.
Credit Risk Department
Legal and Compliance Risk Department