The Federal Housing Finance Agency has issued a request for comments on the National Survey of Mortgage Originations (NSMO).  I write to support this proposed collection, but also to raise some concerns about its efficacy.

The NSMO is very important to the health of the mortgage market.  We need only look at the Subprime Boom of the late 1990s and early 2000s to see why this is true:  subprime mortgages went from “making up a tiny portion of new mortgage originations in the early 1990s” to  “40 percent of newly originated securitized mortgages in 2006.” During the Boom, subprime lenders like Countrywide changed mortgage characteristics so quickly that information about new originations became outdated within months. Policymakers and academics did not have good access to the newest data and thus were operating, to a large extent, in the dark.  The information in the NSMO will therefore not only help regulators, but will also assist outside researchers to “more effectively monitor emerging trends in the mortgage origination process . . ..”

Notwithstanding the concerns expressed in this comment letter, there is no question that this “collection of information is necessary for the proper performance of FHFA functions . . ..” Given the likely changes to the federal role in the mortgage markets over the next four years, the NSMO can provide critical insight into whether homeowners feel that that market serves their needs.