Another change has to do with how we define the loans that we most want to cover. Our principal goal was to cover the vast bulk of the subprime market, where most of the problems have been and where consumers may need the most protection. The challenge is that there is no one accepted definition of what makes a loan "subprime."
We anticipated, and received, a number of comments about this problem and sought solutions. We looked at available sources of data on mortgage rates and concluded that the best source for our purposes is a survey called the Primary Mortgage Market Survey®, published by Freddie Mac.