Change Lending Review 2026: CDFI Dispute and DSCR Loan Data

Which company is Change Lending

Change Lending, LLC is a California limited liability company organized in 1993, with its principal office at 175 N. Riverview Drive in Anaheim. The SEC’s EDGAR database (CIK 1840132) lists its former name as Commerce Home Mortgage, LLC. Its website footers show NMLS ID 1839 and two trade names: Change Wholesale, the channel for mortgage brokers, and Change Home Mortgage, the retail channel. Its parent is The Change Company CDFI LLC, a Nevada company that the May 2024 offering memorandum says owns 100% of the common units and is the sole manager. When a news story, a securitization or a lawsuit says “Change”, check which of the three names is meant.

The company describes its business as “focused on non-QM loans”. HMDA agrees on the mix: in 2025, 2,586 of its 8,804 originations were flagged business-purpose and 6,218 were not, and the file also shows FHA, VA and conventional loans. The memorandum names 48 states in which the company is licensed to originate mortgage loans, and the District of Columbia as another regulator. In 2025 HMDA, loans appear in 47 states and the District of Columbia and none in Massachusetts, Missouri or New York (our count). The lender’s licensing list for business-purpose loans marks exactly those three, plus Vermont, as “Not yet licensed”; Vermont has one 2025 loan, which is not business-purpose.

The Treasury dispute, in dates

The record has two kinds of source. The court’s own documents are the Joint Request (Docket 16), the Stipulation (Docket 17) and the Orders (Dockets 15 and 19) in Change Lending, LLC v. United States Department of the Treasury, Community Development Financial Institutions Fund, No. 8:23-cv-01626 (C.D. Cal.). The rest is the company’s own account, in a May 2024 offering memorandum and press releases, and trade-press reports. The Treasury has not, in anything we found, published its side.

One premise to correct: the designation was not “lost” in the sense of ending. The Fund moved to remove it, the restraining order froze the position 15 days later (our arithmetic), and the Fund’s list today carries the name. The order of September 11, 2023 also says the Fund’s actions “do not prohibit Plaintiff from continuing to make loans to consumers” and that no party would “retroactively decertify Plaintiff” for the period covered. HousingWire’s line that a judge “sided with Change” in September is a reading of that restraining order, which was entered before any hearing; the docket entries we could read show no ruling on the preliminary injunction before the dismissal.

What the settlement says, and what it does not

The public text is the Joint Request of November 15, 2023, filed in court. It says the settlement “confirms that Plaintiff is and remains” a certified CDFI in good standing with the Fund, that Change “is compliant with its lending obligations” for its fiscal year 2023 report, that the parties will “engage in a good faith meet and confer process” on any issue with Change’s January 2025 application before any action, and, in the filing’s own words:

“The Parties’ settlement also contains a mutual release and an acknowledgement that neither party has admitted fault, error, or liability.”

Three limits follow. First, nobody admitted anything and no court decided who was right, so this page does not say whether the Fund or the company was right in 2023. Second, the agreement is not public; what we have is a two-page filing and a press release from Change that adds that the Treasury “is not aware of findings or recommendations pursuant to which the CDFI Fund could take action against Change” as of the agreement’s date. Third, the reasons for the 2023 action are the company’s account: the memorandum names Target Market benchmarks for January to May 2023, while HousingWire, citing Barron’s, says the lender missed its underserved-lending requirement in 2022. The two accounts differ and neither is a Fund document.

Where the designation stands in October 2026

The CDFI Fund’s list “as of September 17, 2026” has 1,281 certified CDFIs. It names Change Lending, LLC, Anaheim, California, type Loan Fund, and does not name The Change Company CDFI, LLC, which was on the list attached to Change’s August 2023 court application (1,463 entries as of August 15, 2023). We do not know why the certified name changed.

The Fund’s own rules explain why the date matters. Under 12 CFR 1805.201(a) the Fund “in its sole discretion” can decertify an entity that no longer meets the eligibility requirements, and a September 6, 2024 Fund notice required every certified CDFI to reapply under a revised application by a deadline tied to its fiscal year, the last general window closing December 31, 2025, with the warning that an organization that misses its deadline “will lose their CDFI Certification.” The same notice describes a “60% Target Market benchmark.” The list now carries a note that the Fund is “actively reviewing” applications “including pending applications from currently Certified CDFIs.” So the honest status is: listed as certified on September 17, 2026; outcome of the reapplication not stated on the list. We found no announcement of the reapplication result, and the settlement set no date for a decision, only that Change “will remain a certified CDFI until the CDFI Fund’s determination relating to the 2025 application”, in the company’s release.

What CDFI status does and does not change for a DSCR loan

Two federal rules do different jobs, and a DSCR loan falls under the second.

• For consumer loans, CDFI status switches off the ability-to-repay rules. 12 CFR 1026.43(a)(3)(v)(A) lists a creditor “designated as a Community Development Financial Institution” among the lenders to which the underwriting and qualified-mortgage paragraphs (c) through (f) do not apply. The company’s memorandum says that if it lost the status it “may no longer be exempt from the ATR Rules.”
• For business-purpose loans, Regulation Z does not apply at all. 12 CFR 1026.3(a)(1) exempts “an extension of credit primarily for a business, commercial or agricultural purpose.” Change’s investor guidelines make the borrower certify that “consumer protection laws applicable to consumer loans will not apply to their business-purpose loan”, naming the Truth in Lending Act among others.

So a DSCR borrower does not lose a legal protection if the designation changed; the investor loan never had that protection. What CDFI status does for the lender is funding. The memorandum says that without it the company “may have to retain a five percent risk of loss” in securitizations and “may not have enough liquidity to engage in securitizations”, and Change sold almost all of its DSCR-type loans: 1,967 of the 2,123 DSCR-type loans (92.7%, our arithmetic) went to a private securitizer within 2025, against 22.4% for all lenders. A dispute that threatened securitization was therefore a threat to the supply of these loans and their pricing.

What the federal loan file shows: 2022 to 2025

HMDA obliges lenders to report each application. These figures are from the public loan-level file for Change Lending, LLC (LEI 5493004AS1SPBQOFDR49), tabulated by us; “business-purpose” is the lender’s own flag, and nearly all of those loans were on non-owner-occupied property (all of them in 2022 to 2024, 2,584 of 2,586 in 2025).

Three readings:

• The book shrank, then rebuilt. Originations fell 28% from 2022 to 2025 and dollars 19% (our arithmetic), but the 2025 count is 63% above 2024 (our arithmetic). In 2025 the file also records 283 loans purchased from others, none in the three earlier years.
• Business-purpose lending is the growth line. It went from 8.8% to 29.4% of loans. The 2023 figure is a trough of 329 loans, and for that year the debt-to-income field is filled on every one, which is why our DSCR-type filter, which needs it blank, finds none in 2023 and we show 2025 only below.
• Rates tracked the market. The business-purpose median went 5.65%, 9.0%, 7.625%, 7.25%. These are note rates; HMDA does not show points, broker compensation or the prepayment term on these loans.

The 2025 DSCR-type book against the market

HMDA does not label DSCR loans. We use the same filter as our ranking of DSCR lenders by loans: originated, business-purpose, one to four units, non-owner-occupied, first lien, closed-end, term of 360 months or more, and no debt-to-income ratio. That is a proxy: it also takes in other investor products that carry no income test. On it, Change Lending ranks 22nd of 465 lenders by loans and 18th by dollars.

The mix is purchases and cash-out refinances: 1,310 purchase loans, 575 cash-out and 238 rate-and-term refinances. Of the 2,123 loans, 1,733 are on one unit, 243 on two, 72 on three and 75 on four. Only 27 are adjustable-rate; the guidelines also list 5/6 and 10/6 SOFR adjustable products, but the file shows fixed-rate loans dominate.

Price by size and leverage. The table splits the 2,123 loans.

The readings: size barely moves the price here (the sub-$150,000 median equals the $250,000 to $499,999 median), unlike the 1.1-point premium on small loans that we measured at Acra Lending with a different filter, so do not subtract the two pages. Leverage and interest-only each cost a little: the median rate for loans above 75% loan-to-value is 0.255 percentage points above loans at 65% or less (7.25% minus 6.995%, our arithmetic), and interest-only loans carry 0.125 points over amortizing ones. 771 loans, 36.3% of the book (our arithmetic), are above 75% loan-to-value. Change’s 378 California loans are also in our California DSCR page.

Denials. Of the 425 denied DSCR-type applications, the first reason listed was collateral in 181 (42.6%, our arithmetic), “other” in 92, credit history in 49, incomplete application in 43 and unverifiable information in 34. That is a property-first pattern, which fits a product that qualifies the building rather than the borrower’s income.

A target-market check through HMDA

The Fund’s “60% Target Market benchmark” is the kind of test the 2023 dispute was about; the company’s own account speaks of “Target Market benchmarks”. HMDA cannot reproduce it: the Fund assesses by methods HMDA lacks (disability and caretaker status, investment areas, borrower income adjusted for family size). But HMDA shows three things that overlap with the populations Change names in its memorandum (Black or African American, Hispanic or Latino, Filipino, Vietnamese, disabled, low-income and low-income communities). All shares are of loans originated.

The company says that “over 70%” of its loans since it became a CDFI went to “Black, Latino, and low- and moderate-income borrowers and communities.” Our union is lower, 48.5% in 2025, and has fallen every year. Why the number is a floor and not a verdict: applicant race is recorded as “not available” on 1,318 of the 8,804 loans in 2025 (15.0%, our arithmetic); income is reported on only 4,773, so low-income borrowers are undercounted; disability and other Fund categories are missing; and the Fund’s measurement period and method differ. Read it as a pointer to why recertification mattered to this lender, not as evidence of non-compliance.

What the lender says it offers

These terms are from the Change Wholesale Investor Alt-QM Underwriting Guidelines effective May 1, 2026 and its Investor page. They are written for brokers and are not a quote; a rate sheet is separate.

The prepayment line is the one HMDA cannot check: the prepayment-term field is “NA” on all 2,123 DSCR-type loans, so the file gives no evidence about how often the charge is used. The guideline wording ties the charge to the 12th through 60th payments; ask your broker for the schedule in writing, because state rules change it. The DSCR option also requires the borrower to sign a Business Purpose & Occupancy Affidavit, the document that records the business purpose.

Funding: the May 2024 memorandum and the SEC notices

On May 9, 2024 Change Lending, LLC offered to exchange new preferred units for the unsecured notes of its parent, The Change Company CDFI LLC: $18.5 million and $131.5 million of 5.375% notes and $67.75 million and $7.25 million of 4.75% notes, $225.0 million in all (our arithmetic), with the offers set to expire at 5:00 p.m. New York time on June 20, 2024 unless extended. The document also discloses, as of March 31, 2024, a secured debt balance of $3.2 billion, of which $0.9 billion matures within a year, $0.2 billion of unsecured debt and about $30.6 million of available cash at the parent, and a planned private placement of up to $25 million of 12.0% Class D units.

The result is in the SEC’s EDGAR database. Change Lending, LLC (CIK 1840132) has filed five notices of exempt offering (Form D), the last on July 10, 2024. That one reports a Rule 506(b) offering made “in connection with an exchange offer”, first sale June 25, 2024, with $143,750,000 of the $226,500,000 total (measured as the face value of the notes) exchanged by 76 investors, $82,750,000 not exchanged and $2,875,000 of sales commissions. That is 63.5% of the face value exchanged (our arithmetic). The earlier notices report $81.5 million of Class B units sold to 18 investors (filed January 12, 2021), $45 million of debt sold to four investors (filed June 2, 2021) and $129.5 million of Class B units sold to 28 investors (amendment filed April 15, 2022). Change Lending, LLC files nothing else with the SEC that we could find, so the memorandum and these notices are the last primary financial documents in view, all written by the company.

Complaints and court records

CFPB complaints: none under four Change names. On October 21, 2026 we searched the CFPB Consumer Complaint Database company field for “Change Lending”, “Change Company”, “Change Home Mortgage” and “Change Wholesale” and each returned 0. The same search for “Acra” returns 139, so the method works. A zero means no complaint is filed under those names; it does not mean none exists under another name, and business-purpose borrowers may use the CFPB channel less often. See is this DSCR lender legit? for how we read the database.

Court records. Besides the CDFI case, the federal docket shows a False Claims Act case, No. 2:23-cv-00495 (C.D. Cal.), filed January 23, 2023 by a company named Relator LLC against several defendants including Change Lending, LLC. The docket shows sealed filings extending the seal and the government’s election period in October 2024 and April 2025, service on Change Lending, LLC on October 23, 2025, and on December 16, 2025 an order dismissing the case “with prejudice as to Relator LLC and without prejudice as to the United States.” The complaint’s allegations are not in the public docket text we could read, so we do not describe them and draw no conclusion. We did not review consumer suits against the company.

What a reader can do with this

• Confirm who funds your loan. Ask your broker whether the lender is Change Lending, LLC and look up NMLS 1839 on NMLS Consumer Access. The business-purpose licence list names Massachusetts, Missouri, New York and Vermont as not yet licensed.
• Ask for the prepayment term in writing. The guideline allows six months’ interest on the part of a payoff above 20% of the balance, between the 12th and 60th payments; get your own schedule and the state rule before you lock.
• Price it against another lender on the same day. Change’s 7.125% median is below the 7.375% market median, but the rate depends on leverage: loans above 75% loan-to-value had a median of 7.25%. For terms across lenders see DSCR loan rates 2026 and DSCR loan requirements 2026; for the product itself see non-QM loans 2026.
• Check the CDFI Fund list yourself. It is updated periodically and the September 17, 2026 version is the one we read; a lender’s status in the future is the Fund’s decision.
• Do not read the 2023 dispute as a finding. Nobody admitted fault and no court decided who was right; it is context for a lender whose funding depends on a federal designation.

FAQ

Sources, read October 21, 2026: the docket and filings in Change Lending, LLC v. United States Department of the Treasury, CDFI Fund, No. 8:23-cv-01626 (C.D. Cal.), Dockets 8, 15, 16, 17 and 19, and the docket of No. 2:23-cv-00495 including Docket 64 (CourtListener RECAP); the CDFI Fund list of certified CDFIs as of September 17, 2026, the list attached as Exhibit 32 to Change’s 2023 application, and Fund notices of June 20 and September 6, 2024; 12 CFR 1026.3, 1026.43, 1805.104 and 1805.201 (eCFR); the Change Lending, LLC offering memorandum of May 9, 2024 and its five Form D filings and filing list on EDGAR (CIK 1840132); Change’s press releases of November 15, 2023 and February 7, 2024 (BusinessWire and thechangecompany.com); HousingWire reports of August 28, November 3 and November 16, 2023; the Change Wholesale Investor Alt-QM Underwriting Guidelines of May 1, 2026, its business-purpose licensing list and its Investor, home and Change Home Mortgage pages; FFIEC HMDA loan-level data for 2022 to 2025 (LEI 5493004AS1SPBQOFDR49) tabulated by us with action taken = 1 for originations, and our nationwide HMDA tabulation of October 20, 2026; the CFPB Consumer Complaint Database search API. This is analysis of public records, not investment, legal, lending or tax advice. We have no commercial relationship with Change Lending; Kiavi is a paid link.