As
red-blooded American males prepare for the advertising onslaught
of Valentine's Day (2/14), we are reminded that the media is
indeed powerful - just ask Sarah Palin. (Hey, whatever happened
to her?) All this month the public has seen the OCC foreclosure ads.
Supports Independent Foreclosure Review Program with Public
Service Ads. On January 4, the Office of the Comptroller of the
Currency (OCC) announced that it placed print and radio public
service advertisements to inform mortgage borrowers of the
Independent Foreclosure Review (IFR) program launched by the OCC
in November 2011. The print feature explains that borrowers
foreclosed upon between January 1, 2009 and December 31, 2010
are eligible to have their foreclosures independently reviewed
to determine if the borrowers suffered financial injury as a
result of any errors by certain large, federally regulated
mortgage servicers. The ads will run in Spanish and English in
7,000 small newspapers and on 6,500 small radio stations. For a
copy of the OCC announcement with links to the ads, please see http://www.occ.gov/news-issuances/news-releases/2012/nr-occ-2012-1.html.
Hiring
across
the country continues for some companies. SecurityNational
Mortgage’s Crown Group is hiring retail loan consultants,
retail producing managers, and branch managers for its Retail
origination team, and wholesale AE’s who can build their
territory through wholesale, correspondent and retail branch
originations. The company is staffing up in the following
territories - Texas (DFW), Florida (Dade, Broward, Palm Beach
and Duval counties), Missouri, Oklahoma, New Mexico, Arkansas
and Colorado. (SNMC is also hiring underwriters and processors
in the Dallas area.) “SecurityNational Mortgage is a nationwide
lender offering Conventional, FHA, VA and USDA loans thru its
Retail, Wholesale and Correspondent business channels.” If you
know anyone interested, please send inquiries/resumes to CrownGroup@Securitynational.com.”
The
other day someone told me that there were actually things on the
internet other than dirty pictures. I was stunned. Seriously,
although the article is a little slanted, here is some chatter
on on-line lending:
http://www.reuters.com/article/2012/01/23/us-housing-onlinemortgage-idUSTRE80M1X720120123.
The average LO probably doesn’t care too much about the proposed
settlement between the states and the servicers. But the large
servicers, which are pretty much the large banks, care, and
probably really want to “move on” from this, which in turn would
help return the flow of business. At this point, supposedly state AG
negotiators have reached the final terms on a settlement deal
w/the country’s biggest banks, and the preliminary pact is
now being circulated among the 50 AGs. The price tag for the
servicers is around $25 billion, depending on how many states
sign on (California and NY remain on the fence). The tentative
agreement still must be approved by all 50 state
attorneys-general, and the states will be asked either to agree
to proposals or decline to participate with Bank of America,
JPMorgan Chase, Wells Fargo, Citigroup and Ally Financial. Other
banks, such as US Bancorp and PNC Financial Services, have set
aside reserves for such an outcome. Stay tuned…and remember that
the money has to come from somewhere…
Speaking
of
which, the FHFA noted
that forgiving mortgage debt on Fannie Mae and Freddie Mac
loans would cost F&F almost $100 billion. Freddie
& Fannie guarantee nearly 3 million mortgages on single-
family homes that are underwater, but almost 80% of these
borrowers are still current. Principal forgiveness would
increase the size of the government’s bailout of the companies,
which have cost taxpayers more than $153 billion since they were
taken under government control in 2008. One can almost hear Mr.
DeMarco thinking, “First you made us raise our g-fees, and now
this…don’t complain when we lose more money…” For the letter go
to: http://www.fhfa.gov/webfiles/23057/FHFAltrPrincipalForgiveness12312F.pdf.
And
for more on government mortgage agencies, late last week HUD
released its final rule to improve and expand the risk
management activities of the FHA. It was pretty much as expected
but a few things should be noted. First, HUD will seek to force
indemnification for "serious and material" violations of FHA
origination requirements. For those cases not involving
fraud or misrepresentation, HUD will require indemnification
within five years from the date of the mortgage insurance
endorsement. Second, the
proposed rule will also require delegated FHA lenders to
continually maintain an acceptable claim and default rate,
both to gain special lender status as well as to preserve it.
HUD will require that the claim and default rate for a lender be
at or below 150% of the average rate of all of the states in
which it does business. Specifically for indemnifications, HUD
says that lenders may need to buyback loans if they failed to
verify and analyze the creditworthiness, income, and/or
employment of the borrower, verify the source of assets brought
by the borrower for payment of the required down payment and/or
closing costs, address property deficiencies identified in the
appraisal affecting the health and safety of the occupants or
the structural integrity of the property, or ensure that the
property appraisal satisfies FHA appraisal requirements. HUD may
seek indemnification irrespective of whether the violation
caused the mortgage default. Clearly, the rule change should
result in more putbacks to lenders going forward.
What
does this mean? Since HUD will be requiring a buyback only if
the loan has seasoned less than 5-years (unless there is fraud),
similar to GSE loans, this
may lead to a reluctance from lenders to refinance existing
FHA loans due to the fear of resetting the seasoning on the
loan. Further, this impact is not restricted to loans that
are seasoned more than 5-years as the seasoning is reset on all
loans. Although this change points towards a general tightening
in underwriting and a potential slowdown in prepays, experts are uncertain how
putbacks will be implemented for loans that go through FHA
streamline refinancings. For these loans, FHA does not
require an appraisal or income/asset verification and hence it
is not clear what criteria will be used for the putback. That
said, most believe that lenders will be more careful in
refinancing borrowers once this rule goes into effect. Since
lenders will be assessed on the credit performance of their
overall FHA book, this should also lead to lower delinquencies
and defaults on newly originated FHA loans going forward.
And
put another way, the FHA’s rule makes it tougher to qualify for
loans insured by the agency. To qualify for mortgage insurance,
lenders must offer up evidence that their seriously delinquent
and claim rates remain at or below 150 percent of aggregate
rates in home states. And the rule authorizes more extensive
examination for lenders in order to ensure that they are able to
meet the FHA’s new qualifications. It requires that certain
lenders indemnify HUD in claims over loans. And let’s not forget
that many believe the FHA fund is insolvent – perhaps this will
help.
The
government has trouble not interfering with home lending in the
U.S., and in fact HUD has come out saying it would like to see
FHA lenders relax their credit score minimums allowing more
borrowers to qualify for FHA loans. But lenders are telling HUD
officials the agency must first change FHA's lender/monitoring
system (“Neighborhood Watch”) so they aren't stigmatized for
making loans to borrowers with lower credit scores. Neighborhood
Watch ratios are used by everyone to measure performance in
relation to other lenders in a certain geography, and a high
default and claim rate can trigger audits by FHA or the HUD
Inspector Generals, and these audits often lead to
indemnification demands for actual and future losses. Because of
the Neighborhood Watch "triggers", many lenders are only
comfortable originating high credit score FHA loans. Other
lenders are interested in venturing a little down the credit
quality curve, and will often bring in outside help in making
sure their originations, operations and quality control
procedures can withstand the scrutiny of the HUD's Quality
Assurance Division, Mortgagee Review Board and the Office of the
Inspector General. The Collingwood
Group LLC has been partnering with lenders in navigating
these issues to unlock this valuable product development
opportunity in ways that are responsible and defensible.
Inquiries should be directed to Brideen Gallagher at bgallagher@collingwoodllc.com.
(And nope, this is not a paid ad.)
For
news moving rates, the two-day FOMC meeting begins today and
concludes with a news conference Wednesday. It is expected that
the Fed will maintain its rock-bottom policy rate, so the
anticipation lies in the new decision to publish rate forecasts
of each district bank out to 2015 to show greater
transparency. Any hint of QE3 from the FOMC tomorrow “will send
mortgages off to the races.” And tonight’s State of the Union
Address has been known to move markets.
Yesterday
MBS prices were nearly unchanged whereas the 10-yr T-note lost
nearly .375 in price and closed at a yield of 2.07%. Today for
excitement we have a $35 billion 2-yr note auction at 11AM MST.
In the early going the
10-yr is down to 2.04% and MBS prices are a shade better.
(Parental
discretion
advised.)
A woman asks her husband, "Would you like some bacon and eggs? A
slice of toast and maybe some grapefruit and coffee?" she asks.
He declines. "Thanks for asking, but I'm not hungry right now.
It's this Viagra," he says. "It's really taken the edge off my
appetite."
At lunchtime she asked if he would like something. "A bowl of
soup, homemade muffins, or a cheese sandwich?"
He
declines. "The Viagra," he says, "really trashes my desire for
food."
Come dinnertime, she asks if he wants anything to eat. "Would
you like a juicy porterhouse steak and scrumptious apple pie? Or
maybe a rotisserie chicken or tasty stir fry?"
He declines again. "Naw, still not hungry.”
"Well,"
she
says, "would you mind letting me up? I'm starving."
If
you're interested, visit my twice-a-month blog at the STRATMOR
Group web site located at