Unfair Gaps🇺🇸 United States

Savings Institutions Business Guide

19Documented Cases
Evidence-Backed

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All 19 Documented Cases

Defective Originations Leading to Repurchases and Loss Mitigation Costs

Hundreds of millions to billions of dollars industry‑wide in repurchase and settlement costs over multiple years; individual institutions have incurred nine‑figure losses

Poor quality in mortgage underwriting—such as inadequate income verification, appraisal errors, or missing documentation—has led to large‑scale buyback demands and settlements for depository institutions selling loans to the GSEs or investors. These quality failures result in repurchase losses, legal expenses, and additional servicing and workout costs.

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Extended Cycle Times from Application to Closing Slow Fee and Interest Recognition

Lost interest income and fee revenue equivalent to several days to weeks of yield per loan; for a portfolio of $500 million of new originations annually, even a 10‑day delay can mean low‑ to mid‑seven‑figure opportunity cost each year

Mortgage origination often takes 30–60 days from application to closing, and delays in document collection, underwriting conditions, and scheduling appraisals/title work postpone when savings institutions can recognize origination fees and begin earning interest. Longer cycle times also increase pipeline fallout and the probability that rate‑locked loans never fund.

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Bottlenecks in Underwriting and Conditions Clearing Limit Origination Capacity

Lost profit on thousands of forgone or delayed loans during peak cycles; a mid‑size institution could easily forgo millions in net interest margin and fee income annually when unable to scale capacity

Underwriting and documentation review are chronic bottlenecks in mortgage origination, constraining how many loans savings institutions can process during peak periods. When capacity is capped by manual underwriting and repeated back‑and‑forth on conditions, institutions forgo profitable loans or push borrowers to competitors.

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Improper Loan Origination Fees and Unrefunded Charges

$25–$100+ million per large institution over multi‑year remediation; ongoing risk of several basis points of mortgage volume annually in forced refunds and foregone fees

Savings institutions have repeatedly been cited for charging mortgage origination, underwriting, and rate‑lock fees that were not properly disclosed, were higher than permitted, or were retained when loans did not close. These practices create both direct refund obligations and downstream revenue loss when institutions must forego or cap legitimate fee income under consent orders.

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