Will Navy Fed’s Outlier HMDA Data Trigger a Fair Lending Exam?
It’s possible. Navy Fed has been offering a 100% LTV mortgage product for which they charge a rate of 5% due to the higher risk and the fact that they waive private mortgage insurance. However, the 5% rate has caused these loans to meet the definition of a higher rate mortgage with the end result being that Navy Fed was the largest higher rate mortgage lender in the country in 2013. [10/1/14]