In a "guidance" regarding home equity loans issued by the Office of the Comptroller of the Currency, the Federal Reserve, the Federal Deposit Insurance Corp., the Office of Thrift Supervision and the National Credit Union Administration, lenders were specifically warned about loans originated by mortgage brokers or other third parties.
Brokers, who are not bank employees and who are paid by commission based on the volume of loans they complete, and correspondents, which make loans on their own for resale to other lenders were identified as risk factors regarding potential future increased delinquency rates.
The guidance noted that active portfolio management was especially important for "financial institutions that project or have already experienced significant growth or concentrations in higher risk products, such as high LTV, limited documentation and no documentation interest-only, and third-party generated loans."
The guidance also suggested that banks stop buying gasoline from oil companies, food from the supermarket, electricity from the electric company and to be sure to roll the boulder in front of the cave opening before turning in for the night.






