The fed's guidelines are just that - guidelines. It was the state's hard / fast rules that made things more difficult. I am not suggesting that we are going to fill up the portfolio with 100% LTV paper. There are clearly S&S issues to consider. If I have an 800+ FICA, 15% Debt / Income, 15 years on the job, I am not going to get bent out of shape about a 91% LTV. That is my reason to dance. I don't really think that I will even change our LTV policy at this point. The change in the state code allows me to make the decision based on my appetite for risk. What a concept!
This post is strictly for your information. I am not about to suggest that anybody change the way they approach LTV.