Restitution/Fraud
As the fraudulent mortgage application wasn't sufficiently proximate to the foreclosure loss suffered by the government lender, restitution order was inappropriate.
http://www.ca5.uscourts.gov/opinions/pub/14/14-51207-CR0.pdf
Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Neither an authoritative statement of the law nor legal advice. Quick work.