The Comptroller’s report found that competitive pressures are driving many banks to further loosen their credit standards.

If lenders instead clamped down on credit standards it would drive housing prices lower.

Agencies that counsel homeowners with mortgage problems say that many borrowers are running into problems because of the terms of their loans, not their personal circumstances.

Here is where the pain is.

David M. Crosby, a Las Vegas bankruptcy attorney, says he has seen a “surge” in borrowers with mortgage problems. “Most of it is [tied to] the end of the housing boom, but I do see a good percentage of clients who got caught by a change in their mortgage rates.” In addition, some clients “bought a number of speculative homes,” he says. “The market turned on them, and now they are in a real financial mess.”