Federal Deposit
Insurance Corporation

Comments to Regulators regarding Proposed Statement on Subprime Mortgage Lending from Neighborhood Housing Services of New York City 

Neighborhood Housing Services of New York City (“NHS”) applauds the efforts of banking regulators to clearly and unequivocally advise lenders of subprime ARMs that they will be held to the same standards as lenders of other non-traditional mortgage products. Requiring institutions to make a good faith assessment of a borrower’s ability to repay a subprime loan, as opposed to simply determining the foreclosure or liquidation value of a borrower’s collateral, will help sustain and create homeownership opportunities for millions of families, reduce the risks of foreclosure and loss of one’s home resulting from predatory lending practices, and ultimately help to stabilize and rejuvenate neighborhoods throughout the country.