ATR mandates a repayment analysis for
closed-end mortgage loans and prohibits certain loan terms and conditions.
Certain depository institutions originating fewer than 25
closed-end mortgage loans or fewer than 100 open-end lines of credit each year may no longer be subject to HMDA's reporting requirements at all.
To simplify the analysis, we focus on consumers who had exactly one
closed-end mortgage with an outstanding balance of at least $50,000 as of the end of 2009 and stayed in the same census block over the course of 2010 (a proxy for not having changed residence; we simply want to omit from the analysis those who moved).
It manages Second Angel Commercial Mortgage Fund l LLC, a $50 million
closed-end mortgage fund that lends money to builders, developers, business and homeowners for short periods of time.
Other anecdotal evidence includes the fact that HFC and American General withdrew from the
closed-end mortgage market because of insufficient profits.