What changed in this filing

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Item 1. Business

2026-02-12 compared with 2025-02-14 · 92 added, 93 removed, 555 unchanged (25% of the section changed)

We provide mortgage insurance (referred to as mortgage insurance or MI) through our wholly-owned insurance subsidiaries, National Mortgage Insurance Corporation (NMIC) and National Mortgage Reinsurance Inc One (Re One).

NMIC and Re One are domiciled in Wisconsin and principally regulated by the Wisconsin Office of the Commissioner of Insurance (Wisconsin OCI).

See the “ Glossary of Abbreviations and Acronyms ” for descriptions of terms used through this annual report.

We provide mortgage insurance (referred to as mortgage insurance or MI) through our wholly-owned insurance subsidiaries, NMIC and Re One.

NMIC and Re One are domiciled in Wisconsin and principally regulated by the Wisconsin OCI.

NMIC is our primary insurance subsidiary, and is approved as an MI provider by the GSEs and is licensed to write MI coverage in all 50 states and D.C.

Our subsidiary, NMI Services, Inc.

(NMIS), provides outsourced loan review services to mortgage loan originators and our subsidiary, Re One, historically provided reinsurance coverage to NMIC in accordance with certain statutory risk retention requirements.

Our subsidiary, NMIS, provides outsourced loan review services to mortgage loan originators and our subsidiary, Re One, historically provided reinsurance coverage to NMIC in accordance with certain statutory risk retention requirements.

Such requirements have been repealed and the reinsurance coverage provided by Re One to NMIC has been commuted.

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MI plays a critical role in the U.S.

housing market by mitigating mortgage credit risk and facilitating the secondary market sale of high loan-to-value (LTV) ( i.e., above 80%) residential loans to the GSEs, who are otherwise restricted by their charters from purchasing or guaranteeing high-LTV mortgages that are not covered by certain credit protections.

housing market by mitigating mortgage credit risk and facilitating the secondary market sale of high-LTV ( i.e., above 80%) residential loans to the GSEs, who are otherwise restricted by their charters from purchasing or guaranteeing high-LTV mortgages that are not covered by certain credit protections.

Such credit protection and secondary market sales allow lenders to increase their capacity for mortgage commitments and expand financing access to existing and prospective homeowners.

NMI Holdings, Inc.

NMIH, a Delaware corporation, was incorporated in May 2011, and we began start-up operations in 2012 and wrote our first MI policy in 2013.

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As of December 31, 2025, we had issued master policies with 2,193 customers, including national and regional mortgage banks, money center banks, credit unions, community banks, builder-owned mortgage lenders, internet-sourced lenders and other non-bank lenders.

As of December 31, 2024, we had $210.2 billion of primary insurance-in-force (IIF) and $56.1 billion of primary risk-in-force (RIF).

For the year ended December 31, 2024, we generated new insurance written (NIW) of $46.0 billion.

As of December 31, 2025, we had $221.4 billion of primary IIF and $59.3 billion of primary RIF.

For the year ended December 31, 2025, we generated NIW of $48.9 billion.

As of December 31, 2025, we had 225 full-time and part-time employees.

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residential mortgage market attracts and involves participation from a range of private and governmental institutions.

Private industry participants include national and regional mortgage banks, money center banks, mortgage brokers, community banks, builder-owned mortgage lenders, internet-sourced lenders, commercial, regional and investment banks, savings

institutions, credit unions, real estate investment trusts and other financial institutions.

Government participants include government agencies such as the government MIs ( e.g.

Government participants include

government agencies such as the government MIs ( e.g.

, FHA, USDA and VA) and Ginnie Mae, as well as government-sponsored enterprises, such as Fannie Mae and Freddie Mac.

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Mortgage Insurance Regulation - GSE Oversight ,” below.

NMIC is approved to insure loans guaranteed by the GSEs and is subject to the PMIERs.

As of December 31, 2025, our PMIERs available assets exceeded our risk-based required assets by 70% (the 'PMIERs sufficiency ratio').

See Part II, Item 7, “ Management's Discussion and Analysis of Financial Condition and Results of Operations - Liquidity and Capital Resources" for additional information.

Mortgage Insurance

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Such credit protection and secondary market sales allow lenders to increase their capacity for mortgage commitments and expand financing access to existing and prospective homeowners.

Our competition includes other private mortgage insurers, government MIs and other alternatives designed to eliminate the need for MI, such as piggy-back loans or front-end risk sharing arrangements that do not require private MI on loans sold to the GSEs.

The private MI industry is highly competitive and currently consists of six active participants, including us, Arch Capital Group Ltd., Essent Group Ltd.

Our competition includes other private mortgage insurers, government-run MI programs, and other alternatives designed to eliminate the need for MI, such as piggy-back loans or front-end risk sharing arrangements that do not require private MI on loans sold to the GSEs.

The private MI industry is highly competitive and currently consists of six approved participants, including us, Arch Capital Group Ltd., Essent Group Ltd.

(Essent), Enact Holdings, Inc., MGIC Investment Corporation (MGIC), and Radian Group Inc.

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We expect the MI market to remain competitive, with pressure for industry participants to grow or maintain their market share.

We and other private mortgage insurers also compete directly with the government MI companies, who significantly increased their share in the MI market following the 2008 financial crisis.

Prior to the financial crisis, private mortgage insurers accounted for the majority of the insured mortgage origination market.

During the financial crisis, the government MIs captured an increasing share of the high-LTV MI market as legacy private mortgage insurers came under significant financial stress.

According to data reported by Inside Mortgage Finance, in 2007, government MIs accounted for 23% of the total insured mortgage origination market.

By 2009, government MI share had peaked at approximately 82% of the total insured mortgage origination market.

Government MI share has since declined and is estimated to have been 58% in 2024.

Previous rate actions and product introductions continue to impact the government mortgage insurers' market share and by extension the private MI market.

Although there continues to be broad policy consensus toward the need for continued and consistent private capital participation in the U.S.

housing finance system, it remains difficult to predict whether the combined market share of government MIs will recede to pre-2008 levels.

A range of factors influence a lender's decision to choose private over government MI, including, among others, GSE demand, policies and loan delivery pricing, mortgage insurance premium rates and other charges, loan eligibility requirements, cancelability, loan size limits and the relative ease of use of private MI products compared to government MI alternatives.

We and other private mortgage insurers also compete with government-run MI programs, including those managed by the FHA, USDA or VA.

A range of factors influence a lender or borrower’s decision to choose private MI over government-run MI alternatives, including, among others, GSE demand, policies and loan delivery pricing, mortgage insurance premium rates and other charges, loan eligibility requirements, cancelability, loan size limits and the relative ease of use of private MI products compared to government MI alternatives.

Private MI and government-run MI programs are estimated to have accounted for 38% and 62% of total high-LTV loan origination volume in 2025, respectively.

Products and Services

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In March 2020, we introduced our current Master Policy (the 2020 Master Policy), which replaced our previous form (the 2014 Master Policy) for MI applications received on and after March 1, 2020.

We implemented the 2020 Master Policy, in part, to provide terms of coverage that conform to the requirements of the GSEs' 2018 revised Amended and Restated Rescission Relief Principles (RRPs).

We implemented the 2020 Master Policy, in part, to provide terms of coverage that conform to the requirements of the GSEs' 2018 revised Amended and Restated RRPs.

The 2020 Master Policy governs the terms of coverage for NIW associated with applications received on or after March 1, 2020.

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however, depending on how the loan is structured, the premium payments may be paid by either the lender or the borrower, notwithstanding that the borrower is not a beneficiary under the terms of the policy.

Policies with premium payments made by the borrower are referred to as borrower-paid mortgage insurance (BPMI) and those with premium payments made by the lender are referred to as lender-paid mortgage insurance (LPMI).

Policies with premium payments made by the borrower are referred to as BPMI and those with premium payments made by the lender are referred to as LPMI.

Lenders may structure loans to recover LPMI premiums from borrowers, including through increases in mortgage note rates or higher origination fees.

Our premiums are based on statutory rating rules and rates that we file with various state insurance departments.

We establish our premium rates based on models that assess risk across a spectrum of variables, including coverage percentages, LTV ratios, loan and property attributes, borrower debt-to-income (DTI) and credit score profiles, and market and macroeconomic conditions.

We have discretion under our rates and rating rules to flex our premium rates to a limited degree, and we may choose

to do so for lenders or programs that meet certain criteria.

We establish our premium rates based on models that assess risk across a spectrum of variables, including coverage percentages, LTV ratios, loan and property attributes, borrower DTI and credit score profiles, and market and macroeconomic conditions.

We have discretion under our rates and rating rules to flex our premium rates to a limited degree, and we may choose to do so for lenders or programs that meet certain criteria.

We generally cannot change premium rates on insured loans after coverage is established.

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GSE guidelines generally provide that a borrower on a GSE-owned or guaranteed loan meeting certain conditions may require their mortgage servicer to cancel BPMI upon the borrower's request when the principal balance of the loan is 80% or less of the property's current assessed value.

The federal Homeowners Protection Act of 1998 (HOPA) also requires the automatic termination of BPMI on most current loans when the LTV ratio (based on the original value of the underlying property and original amortization schedule of the loan) is first scheduled to reach 78%.

HOPA also requires the automatic termination of BPMI on most current loans when the LTV ratio (based on the original value of the underlying property and original amortization schedule of the loan) is first scheduled to reach 78%.

The HOPA also provides for cancellation of BPMI upon a borrower's request when the LTV ratio (based on the original value of the underlying property and original amortization schedule of the loan) is first scheduled to reach or, based on actual payments, reaches 80%, upon satisfaction of the conditions set forth in the HOPA, including that the loan be current at the time.

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NMIS utilizes third-party service providers to conduct individual loan reviews .

NMIS third parties have represented and warranted to NMIS that they comply with the requirements of the federal Secure and Fair Enforcement for Mortgage Licensing Act (SAFE Act) in all applicable jurisdictions.

NMIS third parties have represented and warranted to NMIS that they comply with the requirements of the SAFE Act in all applicable jurisdictions.

See “ Business - U.S.

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Our underwriters are located remotely, providing us the ability to efficiently service our customers nationwide across different time zones.

We also engage third-party underwriting service providers (USPs) who provide us with incremental underwriting capacity.

We also engage third-party USPs who provide us with incremental underwriting capacity.

We train and require our USPs to follow the same processes and underwriting guidelines that our own employees follow when rendering insurance decisions.

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In collaboration with our USPs' management teams, we monitor our USPs' day-to-day underwriting performance and MI decisioning.

We also review the qualifications of each individual underwriter assigned by our USPs to service our account and provide them with NMI specific systems and guideline training to ensure they have the necessary training to render underwriting decisions consistent with our underwriting guidelines and credit policies.

We also review the qualifications of each individual underwriter assigned by our USPs to service our account and

provide them with NMI specific systems and guideline training to ensure they have the necessary training to render underwriting decisions consistent with our underwriting guidelines and credit policies.

Our outsourcing agreements require our USPs to perform and provide us with the results of internal quality control reviews on a periodic basis.

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Delegated lenders who pursue early rescission relief and subject their insured loans to our post-close independent validation process are required to submit a full file (which contains all the underwriting information and documentation otherwise required by us for a non-delegated underwrite and the above-referenced post-close documentation) after a loan's coverage effective date.

We refer to our independent validation of delegated loans as our "Delegated Assurance Review" or "DAR" process.

Through DAR, we assess and validate the MI underwriting process and decisions made by our delegated customers on an

individual loan level basis.

We refer to our independent validation of delegated loans as our “DAR” process.

Through DAR, we assess and validate the MI underwriting process and decisions made by our delegated customers on an individual loan level basis.

Loans from delegated lenders who do not pursue or submit the documentation necessary for us to complete our DAR process remain eligible for 36- or 60-month rescission relief in accordance with the terms of the applicable Master Policy.

All loans, whether included in our post-close validation processes or not, are eligible for review under our quality control (QC) process, and such QC reviews qualify as independent validations for such loans, making them eligible for early rescission relief.

All loans, whether included in our post-close validation processes or not, are eligible for review under our QC process, and such QC reviews qualify as independent validations for such loans, making them eligible for early rescission relief.

We engage USPs to perform the majority of our delegated independent validation work and periodically assist with our non-delegated independent validation work.

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We utilize a proprietary risk-based pricing platform, which we refer to as Rate GPS ® , to establish individualized premium rates for most new loans that we insure based on our modeled view of the relative risk and anticipated performance of each loan.

Rate GPS ® considers a broad range of variables, including property type, type of loan product, borrower credit characteristics, and lender and market factors, and provides us with the ability to set and charge premium rates commensurate with the underlying risk of each loan that we insure.

We introduced Rate GPS ® in June 2018 to replace our previous rate card pricing system.

While most of our new business is priced through Rate GPS ® , we continue to offer a rate card pricing option to a limited number of lender customers who require a rate card for business process reasons.

Rate GPS ® considers a broad range of individual and layered risk variables, including borrower credit, loan-level, product and lender attributes, as well as market and geographic factors, and provides us with the ability to set and charge premium rates commensurate with the underlying risk of each loan that we insure.

We also offer a rate card pricing option to a limited number of lender customers when required for business process reasons.

Our pricing approach targets through-the-cycle returns that exceed our cost of capital.

We believe that Rate GPS ® provides us with a more granular and analytical approach to evaluating and pricing risk, and that it enhances our ability to continue building a high-quality mortgage insurance portfolio and delivering attractive risk-adjusted returns.

We maintain documented model governance and fair-lending controls over Rate GPS ® , including periodic validation and outcome monitoring, to help ensure consistent, risk-appropriate pricing.

Policy Servicing

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Generally, servicers submit reports to us on a monthly basis.

We are currently integrated with the two largest third-party mortgage servicing systems, Black Knight Financial Services and FiServ.

We are currently integrated with the two largest third-party mortgage servicing systems, ICE Mortgage Technology and FiServ.

We are also integrated directly with certain lender customers who manage their own servicing systems.

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We include a loan in our default population and establish claim reserves on such loan when we have received notice from the servicer that as of a particular payment date, the borrower has missed the preceding two or more consecutive monthly payments.

The incidence of default is affected by a variety of factors, many of which are unforeseen, including a borrowers' loss of income, unemployment, divorce, illness or death.

The incidence of default is

affected by a variety of factors, many of which are unforeseen, including a borrowers' loss of income, unemployment, divorce, illness or death.

Defaults that are not cured result in a claim to us.

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We utilize third-party reinsurance to actively manage our risk, ensure compliance with PMIERs, state regulatory and other applicable capital requirements, and support the growth of our business.

We currently have both excess of loss and quota share reinsurance agreements in place.

We currently have both quota share and excess of loss reinsurance agreements in place.

Since 2016, we have entered into the following types of reinsurance transactions which provide risk protection on both a retrospective and prospective basis:

• fully collateralized ILN coverage on mortgage insurance policies that we have already issued with special purpose insurers funding such reinsurance obligations through the issuance of insurance-linked notes;

• XOL reinsurance arrangements with third party reinsurers on mortgage insurance policies that we have already issued;

• QSR arrangements in which third-party reinsurers agree to prospectively reinsure a portion of the risk on mortgage insurance policies that we write;

• XOL reinsurance arrangements with third-party reinsurers on mortgage insurance policies that we have already issued;

We believe that our reinsurance programs offer us a number of benefits, including:

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• conducting diligence of our lender customers before and after we formally engage with them to ensure they have appropriate financial resources, operational capabilities, management experience and a track record of strong origination quality, and subjecting them to well-defined parameters regarding underwriting delegation status, credit guideline requirements and, on a more limited basis, variances;

high risk and targeted basis to measure the quality of the underwriting decision and loan closing process, and specifically assess the accuracy and adequacy of the information and documentation used to underwrite our MI;

• implementing a quality control process to ensure ongoing adherence with our underwriting guidelines and eligibility criteria, under which our quality control group performs audits of insured loans identified on a random, high risk and targeted basis to measure the quality of the underwriting decision and loan closing process, and specifically assess the accuracy and adequacy of the information and documentation used to underwrite our MI;

• setting concentration limits to regulate the aggregation of loan-level risks in our overall portfolio and manage our overall portfolio exposure to certain risk classes that typically experience greater volatility and loss during periods of economic and housing market downturns, such as higher LTV loans, loans with higher borrower DTIs, investor loans, cash-out refinances, certain state concentration levels and several other borrower or loan attributes;

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We utilize and develop technology that enhances our current operating capabilities and supports future growth, while allowing us to realize current efficiencies.

Effective March 31, 2020, we entered into an agreement with Tata Consultancy Services (TCS), under which TCS provides IT services over a seven-year period across such functions as application development and support, infrastructure support and information security.

Our engagement with TCS has enhanced our ability to provide innovative IT solutions for our internal and external constituents, while allowing us to realize cost efficiencies by leveraging TCS's global platform.

Effective April 1, 2025, we renewed and extended our existing seven-year IT service agreement with TCS, dated March 31, 2020, through March 31, 2032.

Under the agreement, TCS provides IT services across such functions as application development and support, infrastructure support, and information security.

Our engagement with TCS has enhanced our ability to provide innovative IT solutions for our internal and external constituents and has allowed us to realize cost efficiencies by leveraging TCS’s global platform.

We describe our cybersecurity risk management program and governance, including third-party risk oversight related to this platform, in Item 1C, “ Cybersecurity .”

Investment Portfolio

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Treasury securities and obligations of U.S.

government agencies, municipal debt securities, corporate debt securities, and asset-backed securities.

We also held short-term investments, such as U.S.

government agencies, municipal debt securities, corporate debt securities, U.S.

agency mortgage-backed securities, and asset-backed securities.

We also hold short-term investments, such as U.S.

Treasury Bills and commercial paper.

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Our investment policies and strategies are subject to change depending upon regulatory, economic and market conditions, and our existing or anticipated financial condition and operating requirements.

We engage a third-party investment manager Allspring Global Investments, formerly Wells Capital Management, Inc., to assist with day-to-day management of our portfolio and implementation of our investment policy.

We engage a third-party investment manager to assist with implementation of our investment policy and day-to-day management of our portfolio.

Human Capital Management

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As of December 31, 2025, 71% of our employee population identified as members of a diverse group, including 54% as women and 35% as racial/ethnic minorities.

We recognize the valuable contributions of key leaders across our organization and engage in regular succession planning efforts in collaboration with the Board of Directors to ensure business continuity and provide ongoing employee development opportunities.

We recognize the valuable contributions of key leaders across our organization and engage in regular succession planning efforts in collaboration with our Board to ensure business continuity and provide ongoing employee development opportunities.

In 2025, we continued to focus on our talented, innovative and dedicated people, investing in our culture with a focus on collaboration, performance and employee education.

In 2024, we were recognized as a Great Place to Work ® for the ninth consecutive year.

In 2025, we were recognized as a Great Place to Work ® for the tenth consecutive year.

Great Place to Work ® is a global authority on workplace culture, employee experience and leadership, and partners with FORTUNE magazine to produce the annual FORTUNE “100 Best Companies to Work For” list.

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Our main telephone number is (855) 530 - NMIC (6642), and our website address is www.nationalmi.com .

Copies of our Annual Reports on Form 10-K, Quarterly Reports on Form 10-Q, Current Reports on Form 8-K and any amendments to those reports are available free of charge through our website as soon as reasonably practicable after they are electronically filed with, or furnished to, the Securities and Exchange Commission (SEC), and can be viewed at sec.gov.

In addition, a written copy of the Company's Business Conduct and Ethics Policy, containing our code of ethics that is applicable to all of our directors, officers, employees and third-party vendor contractors, is available on our website.

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housing finance system.

We are a member of U.S.

Mortgage Insurers (USMI ® ), an organization formed to promote the use of private MI as a credit risk mitigant in the U.S.

We are a member of USMI ® , an organization formed to promote the use of private MI as a credit risk mitigant in the U.S.

residential mortgage market.

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The GSEs have significant discretion under the PMIERs as well as a broad range of consent rights and notice requirements with respect to various actions of an approved insurer.

The PMIERs financial requirements prescribe a risk-based methodology whereby the amount of assets required to be held against each insured loan is determined based on certain risk characteristics, such as FICO, vintage (year of origination), performing vs.

The PMIERs financial requirements prescribe a risk-based methodology whereby the amount of assets required to be held against each insured loan is determined based on certain risk characteristics, such as credit score, vintage (year of origination), performing vs.

non-performing ( i.e.

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In general, higher-quality loans carry lower charges.

Under the PMIERs, approved insurers must maintain available assets that equal or exceed minimum required assets , which is an amount equal to the greater of (i) $400 million or (ii) a total risk-based required asset amount.

The risk-based required asset amount is a function of the risk profile of an approved insurer's RIF, assessed on a loan-by-loan basis and considered against certain risk-based factors derived from tables set out in the PMIERs to gross RIF, which is then adjusted on an aggregate basis for reinsurance transactions approved by the GSEs, such as with respect to our ILN Transactions, QSR Transactions and XOL Transactions.

Under the PMIERs, approved insurers must maintain available assets that equal or exceed minimum required assets ,

which is an amount equal to the greater of (i) $400 million or (ii) a total risk-based required asset amount.

The risk-based required asset amount is a function of the risk profile of an approved insurer's RIF, assessed on a loan-by-loan basis and considered against certain risk-based factors derived from tables set out in the PMIERs to gross RIF, which is then adjusted on an aggregate basis for reinsurance transactions approved by the GSEs, such as with respect to our QSR Transactions, XOL Transactions and ILN Transactions.

The risk-based required asset amount for performing, primary insurance is subject to a floor of 5.6% of performing primary adjusted RIF , and the risk-based required asset amount for pool insurance considers both factors in the PMIERs tables and the net remaining stop loss for each pool insurance policy.

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The Wisconsin OCI may prohibit the payment of ordinary dividends or other payments by our insurance subsidiaries to us if they determine that such payments could be adverse to policyholders.

In addition, our insurance subsidiaries may make or

pay “extraordinary” stockholder dividends ( i.e.

In addition, our insurance subsidiaries may make or pay “extraordinary” stockholder dividends ( i.e.

, amounts in excess of ordinary dividends) only with the prior approval of the Wisconsin OCI.

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Wisconsin has adopted the Risk Management and Own Risk and Solvency Assessment Act, which requires, among other things, that we conduct an Own Risk and Solvency Assessment at least annually to assess the material risks associated with our business and our current and estimated projected future solvency position, and maintain a risk management framework to assess, monitor, manage, and report on material risks.

Additionally, Wisconsin has also adopted the annual enterprise risk reporting and “Corporate Governance Annual Disclosure” requirements of the National Association of Insurance Commissioners' (NAIC) model laws.

Wisconsin has adopted the NAIC’s amendments to the model holding company act that implement the filing requirement for the group capital calculation (GCC).

Additionally, Wisconsin has also adopted the annual enterprise risk reporting and “Corporate Governance Annual Disclosure” requirements of the NAIC model laws.

Wisconsin has adopted the NAIC’s amendments to the model holding company act that implement the filing requirement for the GCC.

The GCC uses a risk-based capital aggregation methodology for all entities in an insurance holding company system.

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Under applicable Wisconsin law and the laws of 15 other states, a mortgage insurer must maintain a minimum amount of statutory capital relative to its RIF in order for the mortgage insurer to continue to write new business.

These are typically referred to as “risk-to-capital (RTC) requirements.” While formulations of minimum capital may vary in certain jurisdictions, the most common measure applied allows for a maximum permitted RTC ratio of 25:1.

These are typically referred to as “RTC requirements.” While formulations of minimum capital may vary in certain jurisdictions, the most common measure applied allows for a maximum permitted RTC ratio of 25:1.

Wisconsin has formula-based limits that generally result in RTC limits slightly higher than the 25:1 ratio.

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Most states, including Wisconsin, have enacted anti-inducement and anti-rebate laws applicable to mortgage insurers, which prohibit mortgage insurers from inducing lenders to enter into insurance contracts by offering benefits not specified in the policy, including rebates of insurance premiums.

For example, Wisconsin prohibits mortgage insurers from allowing any commission, fee, remuneration, or other compensation to be paid to, or received by, any insured lender, including any subsidiary

or affiliate, officer, director, or employee of any insured, any member of their immediate family, any corporation, partnership, trust, trade association in which any insured is a member, or other entity in which any insured or any such officer, director, or employee or any member of their immediate family has a financial interest.

For example, Wisconsin prohibits mortgage insurers from allowing any commission, fee, remuneration, or other compensation to be paid to, or received by, any insured lender, including any subsidiary or affiliate, officer, director, or employee of any insured, any member of their immediate family, any corporation, partnership, trust, trade association in which any insured is a member, or other entity in which any insured or any such officer, director, or employee or any member of their immediate family has a financial interest.

MI premium rates are subject to prior approval in certain states, which requirement is designed to protect policyholders against rates that are excessive, inadequate or unfairly discriminatory.

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Changes in federal housing legislation may have significant effects on the demand for private MI and, therefore, may materially affect our business.

We are also impacted by federal regulation of residential mortgage transactions.

Mortgage origination and servicing transactions are subject to compliance with various federal and state consumer protection laws, including the Real Estate Settlement Procedures Act of 1974 (RESPA), the Truth in Lending Act (TILA), the Equal Credit Opportunity Act (ECOA), the Fair Housing Act, the HOPA, the Fair Credit Reporting Act of 1970 (FCRA), the Fair Debt Collection Practices Act, the Gramm-Leach-Bliley Act of 1999 (GLBA) and others.

Among other things, these laws and their implementing regulations prohibit payments for referrals of real estate settlement service business, require fairness and non-discrimination in granting or facilitating the granting of credit and insurance, govern the circumstances under which companies may obtain and use consumer credit information, establish standards for cancellation of BPMI, define the manner in which companies may pursue collection activities, require disclosures of the cost of credit and provide for other consumer protections.

We may also be impacted by federal regulation of residential mortgage transactions.

Mortgage origination and servicing transactions are subject to compliance with various federal and state consumer protection laws, including the RESPA, the TILA, the ECOA, the Fair Housing Act, the HOPA, the FCRA, the FDCPA, the GLBA and others.

Among other things, these laws and their implementing regulations prohibit payments for referrals of real estate settlement service business, require fairness and non-discrimination in granting or facilitating the granting of credit, govern the circumstances under which companies may obtain and use consumer credit information, establish standards for cancellation of BPMI, define the manner in which companies may pursue collection activities, require disclosures of the cost of credit and provide for other consumer protections.

Housing Finance Reform

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As the GSEs' conservator, the FHFA has the authority to control and direct the GSEs' operations, and the FHFA's policy objectives can result in changes to the GSEs' requirements and practices.

While in conservatorship, each GSE has been subject to the terms of Senior Preferred Stock Purchase Agreements, as amended, with the Treasury Department (PSPAs).

While in conservatorship, each GSE has been subject to the terms of Senior PSPAs, as amended, with the Treasury Department.

Pursuant to the PSPAs, the Treasury Department committed to invest in the GSEs to the extent required for each to maintain a positive net worth.

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On September 14, 2021, the FHFA together with the Treasury Department announced the suspension of certain portions of the 2021 PSPA amendments, specifically those limiting certain GSE lending activities, and that would, among other things, reduce the amount of capital the GSEs are required to hold.

On March 16, 2022, the FHFA adopted the final rule (effective May 16, 2022) (2022 ERCF amendment) that amended the enterprise regulatory capital framework by refining the prescribed leverage buffer amount and credit risk transfer (CRT) securitization framework for the GSEs, which reduced the amount of capital the GSEs are required to hold, including by increasing the capital credit the GSEs receive for the credit risk that they distribute.

On March 16, 2022, the FHFA adopted the final rule (effective May 16, 2022) (2022 ERCF amendment) that amended the enterprise regulatory capital framework by refining the prescribed leverage buffer amount and CRT securitization framework for the GSEs, which reduced the amount of capital the GSEs are required to hold, including by increasing the capital credit the GSEs receive for the credit risk that they distribute.

On January 2, 2025, the FHFA together with the Treasury Department announced further amendments to the PSPAs to help ensure that the eventual release of the GSEs from conservatorship will be orderly and to reflect certain existing practices.

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In anticipation of expected Presidential dismissal as a result of Trump’s second term inauguration, on January 19, 2025, the sitting FHFA Director exited the role.

President Trump has nominated a new FHFA Director who will need successful congressional confirmation prior to assuming the role.

Until such confirmation occurs, an acting Director oversees the day-to-day operations.

President Trump nominated a new FHFA Director who was confirmed and sworn in on March 14, 2025.

The passage and timing of comprehensive GSE reform or incremental change (whether legislative or administrative in nature) is uncertain, making the actual impact on us and our industry difficult to predict.

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Any such changes in how the FHFA engages with and influences the GSEs could have a significant impact on our business.

We compete with the single-family MI programs of the FHA, which is part of the U.S.

Department of Housing and Urban Development (HUD).

We compete with the single-family MI programs of the FHA, which is part of the HUD.

During the financial crisis, the FHA captured an increasing share of the high-LTV MI market as incumbent private MIs came under significant financial stress.

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The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 (Dodd-Frank Act) amended certain provisions of TILA, RESPA and other statutes that have had a significant impact on our business and the residential mortgage market.

The Dodd-Frank Act created the Consumer Financial Protection Bureau (CFPB), a federal agency with responsibility for regulating and enforcing the offering and provision of consumer financial products and services under the federal consumer financial laws.

The Dodd-Frank Act created the CFPB, a federal agency with responsibility for regulating and enforcing the offering and provision of consumer financial products and services under the federal consumer financial laws.

Actions taken or rules implemented by the CFPB have the potential to impact the overall housing finance market, and by extension the private MI industry and our business.

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Ability-to-Repay and Qualified Mortgage Rules

The CFPB issued final regulations, effective in 2014 and subsequently revised, requiring a residential mortgage loan originator to make a good faith determination, at the time a loan is originated, that the consumer has a reasonable ability to repay the loan (ATR).

The ATR rule does not provide comprehensive underwriting standards but does set forth certain factors that a creditor must consider.

The Dodd-Frank Act provides for a statutory presumption that a borrower will have the ability to repay a loan if the loan has the characteristics of a qualified mortgage (QM) as defined in the CFPB’s regulations, which has defined several types of QMs.

The Dodd-Frank Act provides for a statutory presumption that a borrower will have the ability to repay a loan if the loan has the characteristics of a QM as defined in the CFPB’s regulations, which has defined several types of QMs.

The CFPB’s definition of a “General QM” places limits on points and fees, prohibits or restricts certain mortgage features, and generally limits a QM’s annual percentage rate to 2.25 percentage points above the average prime offer rate for comparable loans.

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On July 27, 2023, the U.S.

banking regulators jointly issued a proposed rule that would revise large bank capital requirements.

banking regulators jointly issued a

proposed rule that would revise large bank capital requirements.

On September 18, 2023, the U.S.

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These large banks may also retreat from high LTV lending if the proposal, as drafted, were passed.

However, as of July 10, 2024, the Chairman of the Federal Reserve, as a member of the Basel Committee, made public remarks in favor of issuing a new proposed rule.

The comment period for the proposal, originally scheduled to end on November 30, 2023, was extended to January 16, 2024.

It is expected that the prior proposed rule will not be approved, and that a new proposed rule will be issued.

The full Basel Committee has yet to finalize next steps on a future path forward.

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Mortgage Servicing Rules

Residential mortgage servicing rules under RESPA and TILA, promulgated by the CFPB, went into effect in 2014.

These rules included new or enhanced servicer requirements for handling escrow accounts, responding to borrower assertions of error and inquiries from borrowers, special handling of loans that are in default and loss mitigation when borrowers default, along with other provisions.

Residential mortgage servicing rules under RESPA and TILA, promulgated by the CFPB include servicer requirements for handling escrow accounts, responding to borrower assertions of error and inquiries from borrowers, special handling of loans that are in default and loss mitigation when borrowers default, along with other provisions.

A provision of the required loss mitigation procedures prohibits the servicer from commencing foreclosure until 120 days after a borrower defaults.

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The CFPB has brought a number of enforcement actions under Section 8 of RESPA, including settlements with several private mortgage insurers.

The CFPB's interpretation and enforcement of Section 8 of RESPA presents regulatory risk for many providers of "settlement services," including private mortgage insurers.

Enforcement of Section 8 of RESPA presents regulatory risk for many providers of “settlement services,” including private mortgage insurers.

Mortgage Insurance Tax Deduction

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Upon expiration in 2011, Congress temporarily extended the deduction for each tax year from 2012 through 2021.

Congress has not extended the deduction to the 2022 and 2023 tax years.

Elimination of the private mortgage insurance tax deduction could have the effect of reducing demand for private MI products.

Congress has periodically considered proposed legislation that would make the private mortgage insurance tax deduction permanent, but to date has not enacted any such legislation.

Under the Tax Cuts and Jobs Act (TCJA) enacted in December 2017, Congress increased the standard deduction for individuals and maintained the tax deductibility of second mortgages.

The combination of maintaining the deduction for second mortgages and not extending deductibility for private MI could have the effect of reducing demand for private MI products.

Congress did not extend the deduction to the 2022 to 2025 tax years.

The deduction has now been reinstated permanently, starting with the 2026 tax year.

The federal SAFE Act, enacted by Congress in 2008, establishes minimum standards for the licensing and registration of state-licensed “mortgage loan originators,” as defined under state law.

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The GLBA and related state and federal regulations implementing its privacy and safeguarding provisions impose privacy and information security requirements on financial institutions, including obligations to protect and safeguard consumers' non-public personal information.

GLBA and its implementing regulations are enforced by state insurance regulators and state attorneys general, and by the U.S.

Federal Trade Commission (FTC) and the CFPB.

GLBA and its implementing regulations are enforced by state insurance regulators and state attorneys general, and by the FTC and the CFPB.

In addition, many states have enacted privacy and data security laws which impose compliance obligations beyond GLBA.

These state laws obligate us to protect social security numbers, maintain a comprehensive information security program, submit annual compliance certifications regarding such programs (or an exemption thereto) and notify insurance regulators if a security breach results in a reasonable belief that unauthorized persons may have obtained access to consumer non-public personal information.

These state laws obligate us to protect social security numbers, make disclosures regarding our privacy practices, limit the manner in which we share personal information, honor some requests for the deletion of personal data, submit annual compliance certifications regarding such programs (or an exemption thereto) and notify insurance regulators if a security breach results in a reasonable belief that unauthorized persons may have obtained access to consumer non-public personal information.

For example, New York’s cybersecurity regulation establishes requirements for insurance entities under the New York Department of Financial Services’ jurisdiction, such as NMIC.

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The CFPB and FTC each have authority to enforce FCRA.

FCRA has been interpreted by some FTC staff and federal courts to require mortgage insurers to provide "adverse action" notices to consumers if an application for mortgage insurance is declined or offered at higher than the best available rate for the program applied for on the basis of a review of the consumer's credit.

FCRA has been interpreted by some FTC staff and federal courts to require mortgage insurers to provide “adverse action” notices to consumers if an application for mortgage insurance is declined or offered at higher than the best

available rate for the program applied for on the basis of a review of the consumer's credit.

We provide such notices when required.

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The Fair Housing Act prohibits discrimination on the basis of race, gender and other prohibited bases in connection with housing-secured credit transactions.

Artificial Intelligence Laws

We are subject to an evolving regulatory framework governing the development and use of artificial intelligence (AI) at both the federal and state levels.

In December 2023, the NAIC published a Model Bulletin on the Use of Artificial Intelligence Systems by Insurers which has since been adopted by more than 20 state insurance regulators, including the Wisconsin OCI, and other state insurance regulators have adopted their own insurance-specific AI regulations or guidance.

Several states have also passed, or are currently considering, generally-applicable laws and regulations related to the development and use of AI systems.

These laws, regulations and guidance generally clarify that existing laws apply to AI systems, including consumer protection, civil rights, competition, data privacy, and insurance laws.

In addition, they may in some cases require disclosures, consumer “opt-out” rights, and the development of model governance, risk assessments and other compliance processes.

In December 2025, President Trump issued an executive order articulating a federal policy favoring U.S.

leadership in artificial intelligence through a minimally burdensome national regulatory framework.

The executive order does not establish a comprehensive federal AI statute or directly preempt existing state laws, but directs federal agencies to evaluate state AI regulations, establish a litigation task force to challenge state laws deemed inconsistent with federal policy, consider federal AI reporting or disclosure standards, and develop potential legislative recommendations.

The evolving interaction between federal and state AI regulation and any potential impact remain uncertain.

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What changed 10-K

Item 1. Business