securitizers and loan purchasers ( " assignees " ) liable for the actions of mortgage originators. the securitization market is critical to increasing the resources available to fund home purchases and great care should be taken to ensure that investors in the securitization market can quickly and accurately assess and mitigate the risks, including the compliance risks, of mortgages sold in this market. such laws should be very clearly delineated to ensure that they do not have a detrimental impact on the ability of lenders to securitize loans. specifically, assignees must be able to conduct due diligence and determine whether an originator has complied with the law, so that they can evaluate and price for any risks. finally, the bill would enhance hoepa's protections by prohibiting abusive practices, such as prohibiting the financing of single - premium credit life insurance. hoepa's points and fees trigger would be lowered and additional fees added. these potential actions merit discussion, and we welcome the opportunity to continue to work with congressional staff on these and other provisions in new legislation. conclusion the board is engaged in several activities to assist consumers, and continues to develop rules that will improve consumer disclosures, address unfair or deceptive practices, and help consumers facing default and foreclosure. we look forward to working with congress to enhance consumer protection laws while maintaining access to credit.

than subprime borrowers but still pose more risk than prime borrowers ), the serious delinquency rate has also risen, to 3 percent from 1 percent only a year ago. these patterns contrast sharply with those in the primemortgage sector, in which less than 1 percent of loans are seriously delinquent. higher delinquencies have begun to show through to foreclosures. about 320, 000 foreclosures were initiated in each of the first two quarters of this year ( just more than half of them on subprime mortgages ), up from an average of about 225, 000 during the past six years. foreclosure starts tend to be high in states with stressed economic conditions and to rise where house prices have decelerated or fallen. adjustable - rate subprime mortgages originated in 2006 have performed the worst, with some of them defaulting after only one or two payments ( or even no payment at all ). relative to earlier vintages, more of these loans carried greater risks beyond weak borrower credit histories – including very high initial cumulative loan - to - value ratios and less documentation of borrower income. the recent increase in delinquencies and foreclosures has created personal, financial, and social distress for many homeowners and communities. we encourage servicers of securitized mortgages to reach out to financially stressed homeowners. keeping families in their homes is a matter of great importance to the federal reserve. in fact, the twelve federal reserve banks are working closely around the country with community and industry groups dedicated to reducing homeowners'risks of foreclosure. each of the reserve bank community affairs offices provides significant leadership and technical assistance in this area. i am also pleased to serve as the federal reserve's representative on the board of directors of neighborworks america, which has a program to encourage borrowers facing mortgage payment difficulties to seek help by making early contact with their lenders, servicers, or trusted counselors. neighborworks'center for foreclosure prevention center recently launched a national advertising campaign to raise awareness about its 24 - hour national hotline that connects struggling borrowers with homeownership counselors. since the launch of the campaign this past june, the daily call volume has almost doubled from 1, 000 to almost 2, 000 calls a day. the board's response to problems in the subprime market the federal reserve has primary rule