"To the extent that we have left the impression with the consumer that we are in full control, we have added fuel to the fire," he wrote. "Consumers are holding us accountable for things over which we have no real control."

He also suggested that companies review state rules and regulations governing loan commitments within their borders. Many jurisdictions define the term "commitment" and require certain actions by lenders, he said, while some others prohibit loan brokers from offering rate-locks altogether.

Courson said in the letter that while increased automation and training has helped cut processing time "from months to weeks and sometimes even days," the "sheer volume" of applications from buyers and owners wanting to refinance has "placed an enormous strain" on the system.

In some instances, he said, "we are now faced ... with 45-60 day processing periods for refinancings."

But he also emphasized that the problem is neither structural nor on-going, and is likely to go away when the "sea of applications" begins to recede as rates trend higher.

For now, though, the MBA chairman called on members to "face the issues and answer candidly the questions put to use by consumers and regulators."

"Forthright responses and clear explanations will help our customers understand that, like them, we are victims of circumstances," he wrote.

Courson said that "regardless of whether or not the consumer understands our business, the fact remains that the industry's reputation is being damaged by this inability to process loans within the established time period.

"Consequently, I am asking each of you to take an active role in ensuring that our industry's good reputation is protected and preserved. The foundation of a sound, stable, long-term enterprise requires both public will and high standards of business practice during difficult times as well as during the good times."

Mortgage bankers licensed in Pennsylvania received another reminder letter earlier this month; this one, from the A. William Schenck III, the state's secretary of banking.

Schenck's missive, which also was sent to loan brokers, said his department had received complaints from consumers regarding the failure of bankers to honor lock-in agreements, the illegal offering of lock-ins by brokers and the collection of lock-in fees by brokers, also a no-no in the Keystone State.

Under Pennsylvania law, only funding lenders are allowed to offer rate locks, which must be in writing and contain the expiration date of the commitment, if any, as well as the rate, points and fees. If there is no specific date on which the loan must be closed, the method by which the duration of the lock-in commitment will be determined must be stated.

A broker can provide a lender's lock-in, but may not themselves enter into commitments with borrowers.

The state banking official said his department will investigate the complaints and monitor banker and broker practices regarding lock-ins. When violations are found, he promised, "appropriate enforcement action," including fines and/or license suspensions or revocations, will be taken.