In finalizing the subprime mortgage guidance, federal banking regulators rejected industry requests for flexibility in helping subprime borrowers by refinancing them into another adjustable-rate 2/28 mortgage.The guidance, issued June 29, suggests that workout arrangements should provide permanent affordability, and that lender/servicers might consider converting ARMs into fixed-rate mortgages to provide "financially stressed borrowers with predictable payment requirements." Comptroller John Dugan said the emphasis is on putting borrowers into loans they can afford. "It doesn't do any good to keep putting people into loans that they can't repay," he said. In underwriting subprime 2/28 ARMs, regulators expect lenders to qualify borrowers at the fully indexed rate, "regardless of any interest rate caps that limit how quickly the fully indexed rate may be reached." The payment schedule should be fully amortizing over 30 years, unless it is a balloon loan.

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