Mar. 28: CrossCountry to buy Two Harbors; escrow interest ruling; vendor news; California MBA & advocacy; Saturday Spotlight: Flyhomes BBYS

In industry news, the big are getting bigger and CrossCountry has stepped in to buy Two Harbors (much more below). But on a more micro-level, Lenders, which include loan officers and underwriters, always have their collective eyes on income, debt, net worth, and personal finances. Did you know that at least 73 out of 100 sitting United States senators have a median net worth of over a million dollars, a financial feat that ordinarily applies to just seven percent of the population. There are just 11 senators who (per the median value on their financial disclosures) have a household net worth less than the median of their respective states. Overall, the median net worth (half above, half below) of a United States Senator is $4.4 million, about 70 times that of an average household in the country. Nothing to see here, move along, right? By comparison, the entire Senate and House of Representatives has between $3.4 million in student debt at the low end and at most $8.3 million across all members.

Saturday Spotlight: Flyhomes

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Flyhomes is the industry leader in solving one of the biggest challenges in real estate: how to buy your next home without having to sell your current one first. As the #1 Buy Before You Sell solution provider in the U.S., Flyhomes DREAM Solutions helps top loan officers unlock more opportunities for their borrowers through:

·      D- DTI Buster

·      R- Retire & Downsize

·      E- Equity for Down Payment

·      A- All-Cash Advantage

·      M- Move With $0 Out of Pocket

We operate on a wholesale-only model, empowering loan officers and real estate agents with a variety of Buy Before You Sell solutions available in all 50 states. More than 5,000 buyers have already used Flyhomes to move seamlessly. With $2.2B in funded loans and a growing partner network of 320+ lenders and 30,000+ MLOs, we’re expanding quickly and are proud to offer our solutions nationwide.

Our products give borrowers real advantages: buy with $0 down, reduce their DTI by up to 50%, and make cash-equivalent offers that close in as little as 10 days. And because we’re wholesale-only, there’s no competition with loan officers or agents. We exist to help them win more deals and build stronger client relationships.

Another key difference? Low costs. We’re proud to offer the most affordable Buy Before You Sell solutions on the market. Our programs start with a tiered flat fee, and our loan product pricing is tied to the loan amount, not the departing home’s sale price. This structure keeps costs fair and transparent, giving borrowers access to the tools they need without creating an extra financial burden. It’s a true win-win for both families and the professionals who serve them.

Join our live session on April 3 (Fri) or April 8 (Wed). We’ll walk through how Flyhomes DREAM Solutions empower you and your borrowers to:

·      Unlock home equity to buy their next home before selling the current one

·      Reduce DTI and help them qualify for up to 50% more

·      Remove home sale contingencies and make stronger offers

Save your seat today (Apr 3 or Apr 8) or book a call to learn how Flyhomes solutions can benefit your borrowers and help you close more deals today.

(For more information on having your firm’s extracurricular activities, employee growth, and your charitable side featured, contact Chrisman LLC’s Anjelica Nixt.) 

Ninth Circuit Decision Upholding State Interest-on-Escrow Laws

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“Once again, the courts have rejected the broad preemption standard advocated by the OCC and national banks. By denying rehearing en banc, the Ninth Circuit left intact its October 2025 opinion in Kivett et al. v. Flagstar Bank FSB, reaffirming the appropriately high bar for preemption established by the U.S. Supreme Court in Cantero.

“The OCC has ignored that standard and Congress’s clear direction, instead proposing a much lower threshold to preempt state laws it deems “inefficient,” “inflexible,” or “unusual.”

“State interest-on-escrow laws do not prevent or significantly interfere with national bank powers and have long protected homeowners. The OCC should immediately withdraw its unlawful proposals.”

CrossCountry steps in to merge with Two Harbors

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Two Harbors Investment Corp. (NYSE:TWO) has entered into a definitive merger agreement with CrossCountry Intermediate Holdco, LLC, an affiliate of CrossCountry Mortgage, under which CrossCountry will acquire all outstanding shares of TWO common stock for $10.80 per share in cash, according to a press release statement. The stock currently trades at $11.40, representing a premium to the offer price as the market weighs the deal’s completion prospects.

In a much publicized move, UWM had made an offer for Two Harbors in mid-December. TWO has terminated this previously announced merger agreement with UWM Holdings Corporation (NYSE:UWMC), dated December 17, 2025. CrossCountry agreed to pay the $25.4 million termination fee to UWMC on behalf of TWO. The special meeting of stockholders to approve the UWMC merger, scheduled for April 7, has been canceled.

The transaction combines CrossCountry Mortgage with TWO’s mortgage servicing rights portfolio and its wholly-owned subsidiary RoundPoint Mortgage Servicing LLC. CrossCountry describes itself as the nation’s largest distributed retail mortgage lender.

There is no reason to think that mergers and acquisitions among companies involved in residential lending will stop in 2026. In fact, yesterday I was speaking to Garth Graham at STRATMOR (who has been involved in a number of other deals this year already) and he expects that the full year 2026 M&A market will see more deals than in 2025 or versus the previous two years. This is not an M&A market of only weak companies selling.

UWMC issued the following statement regarding its proposal to acquire TWO.

“The actions by TWO’s management and board do not reflect the best interests of their shareholders. The same team that had to settle a $375 million lawsuit this past summer is at it again. TWO’s decision appears to be driven more by ego, than by sound judgment. The deal for us was a strategy to acquire their servicing book, not their operations, as ultimately there are no operational efficiencies to gain — UWMs operations are best in class. Unlike TWO’s business, which is effectively a melting ice cube, we are in growth mode and will continue to be the market leader for the wholesale channel in support of our broker clients and team members.”

California MBA on how to view advocacy

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The interaction between various governments and residential lending is constant. Paul Giglioti, CEO of the California MBA, has some thoughts and advice.

“Why Policy Looks Different from the Business Side, and Why Advocacy Is Strategy. If you work in mortgage banking long enough, you learn to watch the signals: Rates move, consumers react, the agencies adjust, and the industry pivots. We watch these indicators because they tell us where the market is going, but there’s one signal the industry often overlooks… and ironically, it might be the most predictable one of all: Policy. From the business side, policy isn’t just politics. It’s strategy. And when you start viewing it that way, the entire conversation around advocacy changes.

“Advocacy Isn’t What Most People Think. For some people it brings up images of protest signs, megaphones, and someone passionately chanting in front of a government building. If you’re from my generation or earlier, you might even flash back to history lessons about civil rights movements and advocacy campaigns where people marched loudly for what they believed in.

“In mortgage banking the advocacy that truly moves the needle looks very different. In fact, when done correctly, advocacy becomes far less about politics and far more about strategy. Because the most effective advocacy isn’t about arguing with lawmakers, it’s about educating them. Educating them about how proposed legislation affects lenders, how it affects operations, how it affects capital markets, and ultimately, how it affects the consumer. And when industry professionals participate in that process, something interesting happens. They become more informed themselves. Which means advocacy doesn’t just educate policymakers… It empowers the industry.

”The Regulatory Landscape Is a Market Indicator. At the California MBA and in mortgage banking we are constantly watching the market: We track interest rates, consumer sentiment, we watch housing inventory, and we monitor agency guidance. Those signals help us understand what’s coming next so we can prepare our businesses.

“But here’s a thought that doesn’t get discussed nearly enough: Policy is a market indicator too.

Regulation is constant. It evolves. It changes. And it quietly shapes the environment we operate in just as much as interest rates or housing supply. Understanding that regulatory landscape early allows the California MBA and lenders to adjust workflows, refine strategy, and position themselves for what’s coming. It allows you to run your business with foresight instead of reaction. And that’s where advocacy becomes incredibly powerful.

“The mortgage industry spends enormous energy trying to forecast the future: watching rates, inventory, consumer sentiment, and agency guidance. Yet one of the clearest indicators of where this industry is headed rarely shows up in those forecasts, and that’s policy. When you understand policy early, you’re not scrambling to adjust your business when the rules change.

You’re already prepared. Advocacy isn’t about politics; it’s about knowing the future operating manual for your business before it’s printed.

“Regulation Doesn’t Just Change Markets… It Creates Them. One of the most fascinating dynamics in financial services that we’ve seen at the California MBA is that regulation doesn’t simply constrain industries. Often, it creates entirely new ones. Consider DocMagic, a company built around automating compliant mortgage documents and disclosures. As regulatory complexity increased, from RESPA and TILA to TRID, lenders suddenly needed technology capable of managing compliant documentation and disclosure processes at scale. The regulatory environment created the need. Innovation followed.

“In the non-QM market, when Dodd-Frank introduced the Ability-to-Repay and Qualified Mortgage rules, traditional lending standards tightened significantly. Many borrowers who didn’t neatly fit inside agency guidelines suddenly found themselves without viable options.

The market responded and a new lending ecosystem emerged: Companies like Deephaven Mortgage, Angel Oak, Verus Mortgage Capital, eResi, Athas Capital, and Acra Lending built entire platforms designed to responsibly serve borrowers outside the traditional QM box. The California MBA saw that regulation didn’t eliminate lending opportunity. It created a new market segment. In many ways, regulation has been one of the most powerful innovation engines our industry has ever seen.”

Paul’s note continued. “What This Looks Like in the Real World. You don’t have to look far to see how this dynamic plays out. Take California’s proposed expansion of the Community Reinvestment Act through AB 801. From a policymaker’s perspective, the goal is expanding access to credit in underserved communities. From the business side, lenders immediately start asking operational questions: How will compliance be measured? What reporting expectations might emerge? How will independent mortgage banks be evaluated compared to traditional banks? Those questions aren’t political… They’re strategic. They influence staffing, compliance infrastructure, and long-term planning.

“Another example is wildfire disaster recovery legislation such as AB 238, which expanded mortgage forbearance protections for borrowers affected by California wildfires. The policy provides relief for homeowners navigating catastrophic loss, an important and necessary step. But it also highlights a broader opportunity for the industry: building better systems that help communities rebuild housing faster after disasters occur. And that’s where advocacy becomes more than engagement with regulation… It becomes innovation strategy.

“It’s time for the mortgage industry to start looking at advocacy through a slightly different lens: Your business plan. Advocacy, when viewed strategically, isn’t about fighting regulation. It’s about understanding it, educating lawmakers so policy works in the real world, positioning your organization to adapt, innovate, and grow as the regulatory environment evolves. The mortgage industry doesn’t need more spectators when it comes to policy. It needs participants. Because the companies that understand the regulatory landscape early don’t just survive change. They help shape what comes next.” Thank you, Paul.

Third party providers: always something new

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I will make the claim that no lender can make a loan without having outside software or service help. Who’s doing what?

Docutech announced that its products and solutions are now integrated with ICE Mortgage Technology’s Encompass Partner Connect (EPC) platform via its latest API framework. The framework connects Docutech and ICE solutions in a single integration with improved disclosure tracking support and automated service ordering, streamlining access for lenders and investors leveraging the Encompass digital lending platform.

In a move to help reduce costs and streamline employment verification for mortgage lenders, Experian® announced the launch of the Experian Verify™ Preview Report, a new capability that gives mortgage lenders early visibility into a borrower’s employment data, at no cost. The Experian Verify Preview Report provides lenders with an upfront view of all employers associated with a specific borrower, allowing lenders to see which employment records are available for instant verification through Experian Verify before obtaining a full verification of income and employment report. The solution requires no new integration work and can be requested through the same processes lenders already use to order Experian Verify instant verification reports. As the mortgage industry continues to evolve toward greater automation.

FirstClose™ announced the rebrand of its point-of-sale (POS) experience as XpressEquity, along with a refreshed Encompass® by ICE Mortgage Technology® integration that delivers a streamlined, end-to-end digital workflow for home equity originations. Together, the platform is designed to help Encompass lenders close home equity loans in as little as 5–10 days.

iEmergent’s CEO and COO launched a free webinar series called "From Gaps to Growth" that walks lenders through a practical framework for identifying missed mortgage opportunities in their markets and turning those insights into production strategy. The sessions draw on work iEmergent has done with banks, credit unions and IMBs across the country that are using market-level data to pinpoint where growth actually exists and where lenders may be leaving business on the table. View the full press release here.

In this episode of The Appraisal Update, Bryan and AIVRE CEO Jake Lew break down the latest on UAD 3.6, what it means for your reports and how to stay ahead of the changes. They also take AIVRE's software for a spin to demonstrate how AI helps appraisers handle repetitive tasks, streamline workflows, and free up time to focus on what really matters.

Halcyon, a financial services innovation company specializing in IRS direct data integration and AI-powered imaging income verification, announced a groundbreaking expansion of its integration with Freddie Mac's asset and income modeler (AIM). Halcyon's TrueTax™ solution will become the first platform to deliver a comprehensive tax dataset that combines borrower-provided tax returns data with IRS-sourced tax transcripts through AIM to support the automated income assessment for self-employed borrowers. This capability offers efficiently and accurately calculating qualifying income for self-employed borrowers while protecting against income documentation fraud. By integrating TrueTax's dual source methodology with AIM as a capability within Freddie Mac's automated underwriting system (AUS), Loan Product Advisor^® (LPA^®), lenders can now automate the self-employed income assessment with unprecedented confidence and speed.

Argyle launched 3-in-1 Verification Suite that brings verification of income, employment, and assets together in a single workflow for mortgage lenders. The move expands Argyle’s platform beyond its core payroll-based income and employment verifications into a full verification stack covering VOI, VOE and VOA. View the full press release here.

FundingShield is working with Dark Matter Technologies (Dark Matter®) to expand access to FundingShield’s risk intelligence capabilities within the Dark Matter technology ecosystem’. The work with FundingShield reflects Dark Matter’s ongoing efforts to support lenders with technology solutions designed to enhance operational security and compliance.

nCino announced the launch of Doc VOI, a new feature in the nCino Mortgage Solution that automates income verification from borrower documents like paystubs and W-2s. Many lenders now verify income through direct payroll or bank connections, but those sources don’t cover every borrower. Doc VOI closes that gap by automatically extracting and analyzing income data from borrower documents. It also integrates with Freddie Mac’s AIM Check API so lenders can submit document-derived income for automated assessment earlier in the underwriting process.

Ocrolus, an AI workflow and analytics platform for lenders, announced the general availability of its AI-powered automated conditioning capabilities, launching on April 1^st. Built from the ground up as an AI-native product rather than being bolted onto a legacy workflow, Ocrolus' conditioning engine is deterministic by design, grounded in selling guide requirements and borrower data and adapts over time to each lender's underwriting patterns.

Many readers of this Commentary have small children, or small grandchildren. There are always shifts in parenting… has it gone this far?

Visit www.ChrismanCommentary.com for more information on our industry partners, access archived commentaries, or subscribe to the Daily Mortgage News and Commentary. You can also explore the Chrisman Marketplace, a centralized hub connecting mortgage professionals with trusted vendors and solutions. If you’re interested, check out my periodic blog on the STRATMOR Group website. This month’s piece is titled, “Mortgage Rates Are Not Random.” The Commentary’s podcast is available on all major platforms, including Apple and Spotify.

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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 2026 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.)