My cat Myrtle was always up for a battle with a lizard in the yard. On a larger scale, the ancient Chinese philosopher Sun Tzu said, “Every battle is won or lost before the battle takes place.” Fed Governor Lisa Cook won the last legal round yesterday in her battle to stay with the Fed. Do you think that companies building a factory in the U.S., as we move toward a factory-based economy with a plant taking 5-10 years to build, will face a battle with local authorities on zoning? Does your company foresee any fair lending battles coming up with regulators? Jeff Naimon from Orrick highlights today’s Mortgage Law Today at 3PM ET. (Jeff is a fixture at the legal issues conferences and helped write the MBA amicus brief on the CFPB funding case.) Many groups took credit for the battle surrounding abusive trigger leads. President Trump recently signed it, and now, “Effective March 5, 2026 (six months out), trigger leads will be permissible under the Fair Credit Reporting Act only in limited circumstances during a real estate transaction and only to provide a firm offer of credit.” Today’s podcast can be found here and this week’s are sponsored by CreditXpert. The all-new credit optimization platform that helps you close more loans. CreditXpert is committed to making homeownership more accessible and affordable for ALL. Today’s features an interview with Figure’s Mike Cagney on the company’s successful IPO last week and how decentralized finance is going to change the mortgage industry for the better, and soon.)

Services, Software, and Tools for Lenders and Brokers

Change is never easy, especially when it comes with updated rules, tighter timelines, revised compliance requirements, and added documentation. That’s exactly what servicers faced with HUD’s Mortgagee Letter 2025-12. This update marks a significant shift, transitioning from temporary COVID-era solutions to permanent guidelines that aim to streamline processes and minimize financial risk. Clarifire’s latest blog, “FHA’s New Waterfall: A Real-World Lesson in Why Workflow Matters,” unravels the complexity of these changes set to take effect October 1, 2025, and highlights why servicers leveraging workflow automation are better positioned to adapt quickly and seamlessly. At the same time, those relying on manual processes or single-point solutions that are not configurable scramble to keep up. More importantly, it reveals how workflow applications like CLARIFIRE are flipping the script, transforming regulatory challenges into opportunities for efficiency, compliance, and stronger borrower outcomes. Discover how by reading the blog today, then contact us to learn more or schedule a demo of CLARIFIRE®.

With change comes opportunity. As Accurate Quality Control (AQC) winds down operations, Founder Genny Kelly has chosen to endorse QC Ally as the trusted successor for her clients seeking proven quality control services. Her vote of confidence highlights QC Ally’s long-standing reputation for excellence, integrity, and partnership. QC Ally is committed to ensuring a seamless transition for AQC clients while continuing to deliver the certainty and personalized service they’ve come to expect. From pre-funding and post-close to servicing audits and due diligence, QC Ally provides the full spectrum of mortgage QC solutions powered by proprietary technology and backed by a 100% US-based team. Whether you’re an AQC client or simply looking for a dependable QC partner, QC Ally stands ready to ensure accuracy, integrity, and continuity you can trust. Connect with QC Ally to learn more.

In today’s market, timing and trust are everything. Early Access Soft Check from TransUnion® helps mortgage lenders stay ahead by offering a clearer view of creditworthiness, without impacting consumer scores. That means less risk of losing borrowers to trigger leads, smarter decisions about when to pull tri-merge reports and more confident conversations with homebuyers from the start. It’s a simple shift that can make a big difference in lead conversion and cost control. Learn more here if you’re ready to take a more strategic approach to pre-qualification.

“Running an originations team means navigating a sea of ever-changing compliance rules. When the water gets rough, do you have a life saver you can count on? That’s where MQMR’s Monthly Compliance Support comes in. This program is powered by a team with decades of experience and led by Michael Barone. It’s like having a seasoned crew on board, ready to throw you the answers you need the moment a compliance wave hits. Instead of losing time or momentum trying to interpret regulations on your own, you gain direct access to experts who know the waters inside and out. One client even told us it’s “the best money we spend all year.” With MQMR guiding you, you can sail forward with confidence, keep your focus on growing your business, and leave compliance storms safely behind. Want to learn more? Reach out today!

Last call webinar signup for anyone keeping an eye on borrower experience. Most lenders stop Encompass® automation at the LOS, but that is where friction begins. Manual fee collection, clunky verification requests, and inconsistent credit ordering slow things down for both borrowers and loan officers. Eric Kujala from ICE Mortgage Technology is joining LenderLogix this Thursday, September 18th at 2PM EST to show how lenders are extending Encompass® workflows into the POS to create a smoother borrower journey and more efficient operations. Register now to save your seat!

The Chrisman Marketplace is a centralized hub for vendors and service providers across the mortgage 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.

Wholesale and Correspondent Products

New product alert at Click n’ Close! The 5/1 FHA ARM with SmartBuy™ Down Payment Assistance is ideal for new construction purchases. This product combines flexible financing with support for Builder Forward Commitments, helping you provide affordability and confidence in today’s market. Additionally, CNC added a new 3-Year Forgivable Option to enhance SmartBuy, alongside its popular 5-Year Forgivable program. With competitive pricing, no income limits, and no first-time homebuyer restrictions, SmartBuy solutions broaden access for more borrowers. Click n’ Close’s Wholesale or Correspondent teams plan to attend the MBA Annual Conference in Las Vegas. Reach out to them to discover how their newest product updates can help you build stronger relationships with builders and real estate agents, compete more effectively, and increase volume.

American Financial Resources, LLC (AFR) continues to invest in technology designed to streamline processes, reduce friction, and create a smoother experience for partners and borrowers alike. Recent enhancements include displaying loan estimate fees directly in disclosures, paired with a convenient checkbox for partners to provide comments to AFR’s setup team—giving clients more control from the start. In addition, loan-to-value (LTV) calculations now update in real time as information is entered, providing instant feedback without requiring users to navigate outside the workflow. These upgrades build on AFR’s commitment to deliver intuitive loan submission portals, real-time pricing, and instant updates, helping partners stay competitive and close more loans with confidence. And this is only the beginning. AFR has more innovations on the horizon to further empower its partners and ensure every transaction is as efficient and seamless as possible. Visit afrwholesale.com, 1-800-375-6071 or sales@afrwholesale.com. (NMLS 2826)

“Tired of trying to outsmart the Fed? With NFTY, you don’t have to. Our variable-rate HELOC automatically adjusts with Fed decisions: when rates drop, your borrower’s does too. No more market timing, no stress, just smarter borrowing. But that’s only half the story. NFTY isn’t just the most forward-thinking HELOC in the market, it’s also the fastest. From application to funding, we deliver speed no one else can match, backed by customer service that treats you like more than just a number. Play the Fed game the easy way: let NFTY do the work while you enjoy the wins. Email us.”

Citi Correspondent Lending Bulletin 2025-09 announced Depreciating Markets monthly list updates. Effective for new loan registrations on/after September 14, 2025, Non-Agency Exhibit 1 has been updated. Impacted Manual Section(s) Impacted: Section 1520 - NA Exhibit 1.

Citi Correspondent Lending is reducing the HomeRun program's LLPA to 1.500, effective with new Best-Efforts locks completed on/after Thursday, September18, 2025.

Fifth Third Correspondent Lending news, edition 2025-4-9.12.25, includes the following topics: Investor Connect Availability, Fifth Third Correspondent Lending TPO Connect Portal FAQ, and Trailing/Final Documents Address Update.

Bank Mergers and Acquisitions

Yesterday National Bank Holdings Corporation (NYSE: NBHC), the holding company for NBH Bank, announced the signing of a definitive merger agreement to acquire Vista Bancshares, Inc., the holding company for Vista Bank with operations in Dallas-Ft. Worth, Austin, and Lubbock, Texas, as well as Palm Beach, Florida. “Vista Bank is a full-service commercial bank with $2.4 billion in assets, $2.1 billion in deposits, $1.9 billion in loans, and 11 banking centers as of June 30, 2025. Upon completion of the transaction, the combined company will have approximately $12.4 billion in pro forma assets and $10.4 billion in pro forma deposits. NBH Bank plans to retain the Vista Bank brand in Texas and incorporate across the combined enterprise over time.”

The Importance of Knowing Your Borrower

Over the weekend I received an “MLO VieauxPoint” from Brian Vieaux, CMB, President & COO of FinLocker & Founding ‘Expert’ of MLO Live, suggesting to LOs that they read The NextGen HomeBuyer Report to learn why loan officers must show up earlier.

“The 2025 NextGen Financial Literacy Report delivers a clear message: Gen Z and Millennials want to own homes, but they’re stuck in a cycle of myths, overwhelm, and misplaced trust.

Only 8 percent of respondents knew the minimum down payment for a conventional loan. More than half admitted they delayed financial decisions due to complexity. And while two-thirds say they don’t trust lenders, 71 percent are now going to TikTok for advice, and 61 percent are using AI tools like ChatGPT to research their path to homeownership.

“The opportunity for loan officers is unmistakable. As J.D. Power’s latest origination study confirms, borrowers who connect with a lender earlier in their journey report dramatically higher satisfaction, trust, and loyalty scores. Early engagement isn’t just about lead capture; it’s about creating lifelong clients.

“That means shifting from ‘point of sale’ to ‘point of thought.’ Loan officers must step into the role of trusted educator: busting myths about down payments, teaching through clear visuals, and even collaborating with AI tools to help buyers research smarter. Tools like the FirstHome IQ Financial Literacy Quiz and FinLocker’s KeySteps app give originators a tangible way to nurture readiness while earning trust well before an application.

“In this week’s Loan Officer Life podcast, I sat down with Kristin Messerli, Executive Director of FirstHome IQ, to unpack the key findings of the report and discuss how originators can put them into practice. It’s a conversation packed with insights you can apply immediately. You can listen to the full episode wherever you get your podcasts, and read my extended article on the Chrisman Commentary website for a deeper dive into the research and its implications for your business.” Thank you, Brian! #VieauxPoint

Capital Markets

Fannie Mae, Freddie Mac, and Ginnie Mae continue to play a significant role in supporting first-time home buyers, especially as the share of purchase-originated mortgages has risen sharply in recent years (averaging 81 percent of Agency issuance in 2023 and 2024 compared to 46 percent in the prior three years). Ginnie Mae leads the way, with nearly 70 percent of its 30-year mortgage issuance last year coming from first-time buyers, the highest since at least 2016, while the conventional side has averaged 44 percent since 2017. First-time buyers in Ginnie Mae loans tend to have lower credit scores (averaging 701 versus 727 for repeat buyers) and exhibit higher rates of serious delinquencies after the first year (3.9 percent versus 2.5 percent), compared to 0.6 percent versus 0.4 percent on the conventional side.

While debt-to-income ratios are similar across buyer types in both loan categories, first-time borrowers generally face greater financial vulnerability, which translates into riskier credit performance, especially for Ginnie Mae loans. In the conventional space, repeat buyers are more likely to make early curtailments, thanks in part to using proceeds from a prior home sale, making their loans more attractive for investors seeking reduced buyout risk.

Turning to rates, bonds rallied yesterday ahead of today's start of a two-day FOMC meeting that is expected to conclude with a 25-basis point rate cut. Concerns over tariff-driven price pressures have diminished somewhat, with recent CPI data failing to show any sustained breakout. The idea of an inflationary shock from tariffs has given way to expectations of a slower, more manageable pass-through, extending the timeline for any material price increases, and helping to reduce investor anxiety while providing the Fed with more room to maneuver. With inflation no longer viewed as an imminent threat, the Fed’s focus has clearly shifted toward shoring up labor market conditions.

Still, the broader macro narrative remains fragile. Labor market data, especially the sharp downward revision of over 900k jobs, has cast doubt on the economy’s resilience earlier in the year and highlighted the lagged nature of employment indicators. This reinforces the perception that the Fed’s July pause may have underestimated the extent of labor market softening. Despite relatively steady jobless claims and strong asset markets buoying consumer sentiment, the soft data and disinflationary pressures suggest a more vulnerable economy than headlines might indicate.

Today’s economic calendar is packed with data and began with retail sales (+.6 percent, much stronger than expected; ex-auto +.7 percent) and import/export prices (imports were +.3 percent, much stronger than expected), both for August. Later today brings Redbook same sales for the week ending September 13, business inventories in July, the NAHB Housing Market Index for September, and Treasury activity that will be headlined by $13 billion reopened 20-year bonds. We begin the day with Agency MBS prices unchanged from Monday’s close, the 2-year yielding 3.53, and the 10-year yielding 4.05 after closing yesterday at 4.03 percent.