June 7: MLOs & wisdom; Regulations shifting to states; Rates... here a while; Rental housing increase; Saturday Spotlight: Go Moder
This week and next week the conference agendas are packed, with the MBA’s Chairman's Conference, New Jersey, the MBA Florida, EPM TAG, MISMO Spring Summit, The Gathering, and probably one or two that I don’t know about. It comes down to how much effort you put into the event. After all, how much conjecturing about GSE privatization, the Trump Administration’s impact on the economy, mining your database/portfolio, and controlling your own destiny can an industry stand in two weeks? Cost per loan is a topic, and it is really not expected to drop steeply, especially since compensation is the biggest part of it. What happens if labor costs remain constant or go up? “Substitution,” like DU or LP, or lenders using bots. In a different industry, TechMagic is a Japanese company that produces kitchen robots, specifically the I-Robo2, which cooks food like fried rice and chili shrimp in a tilted, rotating cylindrical pan, automatically adjusting heat, in addition to seasoning and washing the pan. The stir-fry bot requires humans to prep and place the ingredients, with the ability to produce about 30 meals an hour. It’s coming to America as TechMagic pursues a U.S. expansion, trying to capitalize on rising labor costs in the U.S. The company also has its eyes on South Korea, Australia, and Europe. Leasing a bot goes for $1,440 per month after installation costs.
Saturday Spotlight: Go Moder
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Leading with Innovation, Built for Impact
At Moder, we help mortgage companies do more with less, without compromising on quality, compliance, or customer experience. As one of the largest mortgage service providers in the U.S., we’re proud to support lenders, servicers, and investors in tackling their biggest challenges with a combination of deep industry expertise, intelligent automation, and scalable, low-cost solutions.
We know this industry isn’t easy. Volumes shift. Regulations change. Margins tighten. But at Moder, we see complexity as an opportunity to create clarity.
Our approach is grounded in partnership. We don’t believe in “lift and shift.” Instead, we focus on identifying the right opportunities to simplify and streamline processes, starting with low-hanging fruit that delivers quick wins. From there, we build toward long-term, sustainable transformation powered by continuous improvement and smart tech integration.
Reimagining the Mortgage Lifecycle: Moder is a trusted partner to some of the most respected names in the mortgage industry. Our team combines deep domain knowledge with modern technology to help clients improve operations, manage costs, and stay agile in a constantly evolving environment.
We believe transformation doesn’t have to be disruptive. It should be thoughtful, targeted, and always aligned with real business goals. That’s the mindset we bring to every engagement.
Moder supports clients across the entire mortgage value chain, from origination to servicing, specializing in operational transformation with measurable impact. Whether it's process optimization, reducing costs, or driving efficiencies, our solutions are built to meet today’s needs while keeping tomorrow in mind.
What sets Moder apart is our ability to integrate human insight with next-gen technology. Our digital capabilities enhance efficiency and improve decision-making, while our global delivery teams bring precision, speed, and scale to day-to-day operations—so you can stay focused on growth.
What Makes Us Unique
Purpose-Built for Mortgage: With decades of collective leadership experience in the mortgage industry, we understand the details that matter. Our solutions are thoughtfully tailored—not one-size-fits-all.
People + Tech, Working Together: We combine skilled talent with automation and AI to deliver real impact. It's not about replacing people—it’s about empowering them to do more valuable work.
Value-First Approach: We start with initiatives that deliver quick wins and long-term value. Whether you're looking to cut costs, reduce turn times, or scale with confidence, we align with your priorities from day one.
Flexible, Scalable, Reliable: Whether you’re navigating a market shift or preparing for your next phase of growth, Moder evolves with you. Our delivery model is built to scale—and built to last.
More than just a service provider, we act as an extension of your team, bringing insights, innovation, and execution together in one seamless experience.
(For more information on having your firm’s extracurricular activities, employee growth, and your charitable side featured, contact Chrisman LLC’s Anjelica Nixt.)
Don’t hold your breath for lower rates
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Yesterday U.S. Bureau of Labor Statistics report on employment conditions in May came out, and MBA SVP and Chief Economist Mike Fratantoni’s weighed in. “Job growth slowed to 139,000 in May, below the 149,000 average for the past year, and was revised lower by a cumulative 95,000 for March and April. The unemployment rate remained steady at 4.2 percent, but the participation rate dropped, indicating that fewer individuals without a job are actively looking for work. All in, the job market is softening, but not quickly.
“Job gains remain concentrated in just a few sectors, particularly health care, education, and leisure and hospitality. Federal government employment has declined again and is now down by almost 60,000 compared to the start of the year.
“Wage growth remains relatively steady at 3.9% over the past year. At some point, we would expect wage growth to decelerate further if the unemployment rate begins to rise, moving bargaining power from employees to employers.
“These data lined up well with market expectations and are likely to keep the Federal Reserve on hold for the next meeting or two. If the job market does weaken further this summer, as MBA forecasts, there will likely be two cuts to the federal funds target this year.”
Borrowers need LOs with wisdom
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Earlier this week I posted some thoughts from Brian Vieaux for loan officers. Seasoned vet Hunter Marckwardt, EVP with CrossCountry Mortgage in the Bay Area, weighed in with some advice for those in our industry adding value by being people. “All of us experience different chapters in our lives, I for one am feeling like I'm starting a new one. Not sure if its age, job, kids getting close to the work force, or AI. It just feels like I'm heading into a new season, and that season can be scary as hell or exciting, depending on the lens I choose to see it through.
“I hopped on the laptop and looked up the definition of wise and various qualities of people that are considered wise. Here is what it said of wise people. Good judgement: makes thoughtful, sound decisions. Sees the long-term impact of choices. Perspective: Sees beyond the surface. Understands different viewpoints and the bigger picture. Experience based insight: Learns from personal and other’s experiences. Humility: acknowledges limitations. Listens and remains open to learning. Emotional Regulation: Remains calm and thoughtful in difficult situations. Empathy: Considers other’s feelings and needs. Balances self-interest with compassion. Moral Clarity: Has a strong sense of right and wrong. Aligns actions with values.
“When I think of me starting a new chapter in my life, and being aware of how much I don't know, I think of #4, humility. When I think of how I'd like to live the remainder of my life overall I think of using all 7 of these qualities as the filter in how I measure myself and my actions. Up until this exercise, I thought of wisdom as something more obscure, like I know it’s good to be wise, and I know people who I'd consider to be wise, but what specifically is it about them? Now I know.
“Those 7 qualities will be printed, framed, and looked at daily. Whether I get closer to ‘wise’ or not, using those 7 qualities as a guiding light in my own self-evaluation would serve me well.”
Demographic shift
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Suburban America is undergoing a dramatic shift as rental housing becomes more prevalent in areas traditionally dominated by homeowners. Affordability pressures, lifestyle changes, and a growing desire for more space are driving renters beyond city limits, with 203 suburbs in the 20 largest U.S. metros now renter-majority, up significantly in the past five years. Despite a slight decline from the peak in 2018, the overall trend points to a sustained transformation, with more than 6 million suburban households now renting.
This shift is most pronounced in high-density coastal areas, particularly suburbs around New York, Miami, and Boston, as developers increasingly focus on suburban rental projects offering more space and amenities. While military bases skew the top renter-dominated areas, the growing prevalence of renter-majority communities highlights a changing housing landscape. With construction moving away from urban cores and toward suburban expansion, the once-clear divide between city renting and suburban homeownership continues to blur, reshaping the American housing market in the process.
Don’t skimp on compliance
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An enforcement memo earlier this year outlined how the Consumer Financial Protection Bureau's regulatory agenda diverges from that of the previous administration, but, given the bureau's planned reduction in force, it is uncertain whether the agency will be able to enforce these new priorities. “I can say that I want to build a stairway up Mt. Everest, but if I don’t have the money or the manpower…”
From the East Coast Brian writes, “I have recently come to the personal conclusion that President Donald Trump is perhaps the savior of Elizabeth Warren’s CFPB. If not for his actions, her Rules may have been amended.
“I believe that the CFPB, as a government agency, is a necessary evil: Necessary in our industry needs conformity and guidelines but evil in the unbalanced and hostility of the vindictive individuals who wrote the Rules now in place. Sadly, with all the hostility toward small business entities, the self-motivated CFPB employees developed, wrote, implemented, and enforced the CFPB Rules. However, it took the current Trump Administration to permanently solidify the CFPB’s anti-small business rules into the Federal Registry for perpetuity… All of this while repeatedly ignoring SCOTUS for both Trump Administrations (Seila Law v CFPB 2019).
“There is no way to know for certain what ‘would have happened’ if DOGE and Trump didn’t do what they are doing. But I believe that affording the benighted DOGE Team the authority to attempt to ‘dismantle’ the CFPB was worse than a failure of legal and political understanding of procedure with the adverse effect. Eventually, my bet is that the CFPB will rise from the ashes, whether it is in four years or eight years and the backlash with be brutal to our industry and those that violated the Rules (the ones that were never amended).
“Remember, the Congress inexcusably never repealed Dodd Frank. Since DOGE terminated (fired or put on leave of absence) all the CFPB Rule writers, the hostile, incompetent & ignorant CFPB Rules are permanently imbedded in the Federal Registry, again for perpetuity. Worse yet, as best I can tell, most people have no understanding of how to conduct the SBREFA hearings or their impacts to comply with the APA. E&O are not permanent, only the following the APA, SBREFA, and entering the Federal Registry makes it permanent.
“Liz Warren, when she was setting up the CFPB, once told me that she feared the Rules would die by a thousand cuts, that’s why she didn’t want Amendments. President Trump fixed this for her permanently, in my humble opinion.”
Meanwhile, some portion of regulatory power is being picked up by the states.
Effective June 11, 2025, a new New York State law mandates that all licensed lenders, mortgage bankers, and banking institutions provide residential mortgage loan applicants with a standardized pamphlet titled, “What Mortgage Applicants Need to Know.” This disclosure must be provided no later than the third business day after receiving the loan application.
“The New York State Department of Financial Services (NYDFS) will develop and publish the pamphlet on its website. It will be made available in English and the six most common non-English languages spoken by individuals with limited English proficiency in New York. The pamphlet may be delivered electronically to applicants.
“The Pamphlet contents will inform borrowers of their rights, including comparing lender fees and negotiating terms, understanding broker compensation and loan details, receiving timely and accurate disclosures like the Loan Estimate and Closing Disclosure, accessing credit counseling, appraisal rights, protection from deceptive marketing and discrimination, and instructions for submitting complaints to NYDFS and CFPB.
Lenders are advised to “update your internal processes to ensure this pamphlet is delivered by the third business day post-application, watch for publication of the official pamphlet on the NYDFS website, and confirm that your systems and compliance teams are ready to support this requirement across all delivery channels.”
In Pennsylvania, Governor Josh Shapiro recently launched a new, centralized consumer protection hotline, website, and email address to make it easier for Pennsylvanians to report scams, resolve financial and insurance issues, and access help from the Commonwealth. The announcement was part of the Shapiro Administration’s initiative to protect Pennsylvania consumers due to changes occurring at federal agencies.
Thanks to Pennsylvania’s exceptionally strong consumer protection laws, the Shapiro Administration will continue to protect consumers in the Commonwealth, and the new initiative makes it easier than ever for Pennsylvanians to report a consumer-related issue. Pennsylvanians can now call 1-866-PACOMPLAINT (1-866-722-6675), visit pa.gov/consumer, or email consumer@pa.gov to report financial, insurance, and consumer concerns. Whether it’s a denied health insurance claim, a suspicious financial transaction, or a mortgage-related issue, help is now just a call or click away.
In nearby Maryland, the state has just begun charging by loans closed in addition to the annual fee. A few readers sent me examples of the verbiage. “This invoice has been created by Maryland and is due on 6/30/2025. To pay this invoice, you can access it in the Invoice section under the Home tab. The Agency Invoice Number is not provided and contains a charge for Assessment Fee.
“Additional Description of Charge: The mortgage lender assessment is based on the $ amount of MD MCR line AC990 for each quarter of 2024 plus the $ amount of line S590 for Q4 2024. If total amount is below $5MM, assessment is $500; if it is $5MM-below $10MM, assessment is $750; if it is $10MM-below $50MM, assessment is $1,500; if it is the $50MM or more, assessment is total amount x .0000267, subject to a $1,500 minimum and a $50,000 maximum. For information or to dispute your calculation, contact clifford.charland@maryland.gov.”
600 miles to the west, in Illinois, a Federal Court awarded the CFPB more than $43 million against the former owner of a debt-relief company. A federal judge for the U.S. District Court for the Northern District of Illinois awarded the CFPB $2,117,133.28 in restitution and a $41,123,897 civil money penalty against the former owner of a dissolved debt-relief company for violations of the Consumer Financial Protection Act and the Telemarketing Sales Rule.
In the Hawkeye State, Weiner Brodsky Kider tells us that Iowa adopted a mortgage trigger lead law: Iowa recently enacted House File 857 to regulate the use of “mortgage trigger leads” by financial institutions.
WBK also points out “Executive Order Directs Federal Agencies to Deprioritize Enforcement based on Disparate-Impact Liability. In a recent executive order, the President directed that (given limited resources for enforcement, the order’s newly stated policy to eliminate disparate-impact liability, and the asserted illegality of disparate impact liability) executive agencies must ‘deprioritize enforcement of all statutes and regulations to the extent they include disparate-impact liability.’”
On a national level, don’t forget that HUD recently issued ML 2025-13, to revise procedures for HUD Real Estate Owned (REO) properties and the Claims Without Conveyance of Title (CWCOT) post-foreclosure sales process. The ML effectively replaces and reverses policies previously established in ML 2022-01 and ML 2022-08.
KBW summed it up. “The principal changes announced in ML 2025-13 involve shortening or eliminating exclusive purchasing periods previously reserved for owner-occupant buyers, HUD-approved nonprofits, and government entities. For HUD REO properties, the exclusive listing period for these parties is reduced from 30 days back to the original 15 days. More significantly, the separate 30-day exclusive sales period for these same parties within the CWCOT post-foreclosure process has been eliminated. HUD indicated these changes were based on data showing the longer exclusive periods did not substantially increase sales to these buyers and potentially led to property deterioration and increased holding costs.”
Despite the Justice Department's recent decision to halt enforcement actions against cryptocurrency exchange platforms, it remains crucial for financial institutions to continue monitoring these platforms, writes Lenders Compliance Group. The DOJ's move, following high-profile pardons and a shift in focus away from regulatory oversight, signals a broader deregulatory stance under the current administration. While the DOJ will now only pursue culpable individuals, not the platforms they use, this raises concerns about consumer protection, especially given past failures like FTX and Mt. Gox, which resulted in billions in lost customer funds. Regulatory frameworks and protections remain fragmented across jurisdictions, and without enforcement, the risks of fraud, hacking, and loss due to error or lack of oversight persist. Consequently, banks accepting crypto transactions must maintain robust internal controls (including AML testing, training, risk assessments, and written compliance programs) not just to fulfill basic regulatory expectations, but to safeguard against reputational and financial risks in an environment where official oversight may be weakening.
Everyone’s had enough political and mortgage back and forth. How about a little fun in this video, especially for anyone who is a fan of dance? “They don’t make ‘em like this anymore.”
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(Market data provided in partnership with MBS Live. For free job postings and to view candidate resumes, visit the Chrisman Job Board. This newsletter is intended for sophisticated mortgage professionals only. There are no paid endorsements by me. For the latest mortgage news, visit Mortgage News Daily. For archived commentaries, or to subscribe, go to www.ChrismanCommentary.com. Copyright 2025 Chrisman LLC. All rights reserved. Paid job & product listings do appear. This report or any portion hereof may not be reprinted, sold, or redistributed without the written consent of Rob Chrisman. The views and opinions in this newsletter are mine alone unless otherwise specifically stated herein.)