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Aug. 23, 2011: PMI stops MI issuance - who's left? Accenture & Zenta merger; appraisal process in the news; FHA training
Rob Chrisman
Who
is Deven Sharma? He is the latest person to quit his job.
Ordinarily this wouldn't be a big deal, but he was the president of
Standard & Poor's
- the rating agency that stripped the United States of its AAA
credit rating. The newspapers cite people familiar with the
matter (why am I never familiar with any matter?) who say
Sharma's move was in the works well before S&P downgraded
its rating on the U.S., is purely due to organizational changes
and does not have anything to do with the Justice Department
investigating whether the agency improperly rated dozens of
mortgage securities in the years leading up to the financial
crisis in 2008. Citibank’s now ex-COO Douglas Peterson will
replace him.
It
is hard to talk about the government removing itself from the
residential mortgage process when one sees a headline like, "FHA Endorses $10.5
billion in Multifamily Rental Housing Loans." Demand
through the FHA has skyrocketed for FHA-insured financing to
build, rehabilitate or refinance multifamily apartment
properties. FHA has announced that it has endorsed 1,100 loans
for multifamily rental housing loans since last October, with
another month-and-a-half remaining in the fiscal year.
HUD
sends its apologies to those who traveled to Puerto Rico this
week for FHA training
- it was cancelled due to bad weather. (How come "traveled" has
one "l" and cancelled has two "l"'s?) But don't worry, there are
more sessions on FHA appraisals, HECM's, processing, etc.:
tomorrow in Portland (OR), 25th Indianapolis, September 7th
Anchorage, 21st Birmingham, October 24th Boston... Most of it is
paid for by the taxpayer and therefore free to the attendee, but
for more information go to http://portal.hud.gov/hudportal/HUD?src/program_offices/housing/sfh/events/events.
I swear that I did not start any appraisal controversies in the
press last week when I brought up valuation problems, but there
was a coincidental flurry in the press about the subject. Maybe
it was the appearance that NAR keeps blaming "bad appraisals"
for the lack of appreciation in the housing market. Regardless,
the Wall Street Journal came out with one article: http://online.wsj.com/article/SB10001424053111904006104576500170808091148.html.
At which point the appraisal industry appears to have raised up
its head and cried out, "Don't blame us, we're just doing our
jobs!" http://www.appraisalbuzz.com/Appraisal-Foundation-Response
And
regarding
RE/MAX’s survey of 53 cities, “showing that July home sales
dropped 12.7% from the previous month. RE/MAX blamed tightened
lending standards, concern about the overall economy and bad
appraisals that reportedly killed many transactions” I received
this note: “Rob, I would like to comment that just because an
appraisal does not meet the contract price it is not necessarily
a bad appraisal. If more appraisers had considered the market
and just not the contract amount in the past we may not have had
as steep of a fall in values. A ‘good’ appraisal is one that
accurately portrays the market value, which may not always be
the contract price. ‘Low appraisals led to 13% of contracts
being renegotiated below the agreed upon price’ is more accurate
and leads to a buyer paying the market price and not an inflated
price. Appraisers have a challenging job these days and too
often are used as the scapegoat for the loan not closing. Thank
you to Vicky Thompson at CMI Valuation Management Group www.ValuationManagementGroup.com.
After last week’s appraisal notes, I received, "One way to nail
down pull through is to watch appraisal orders and receipt of
the appraisal. I needn't explain the correlation between
ordering an appraisal and pull-through - no appraisal, no loan.
Additionally, we've found that beyond the ordering, the timing
of the receipt of the appraisal really dictates when, not if,
the loan will close. I never thought in a million years I'd be
looking at appraisal ordering and receipt as a gage for
fundings."
“Once
Fannie
and Freddie have all of the information on your house, and all
of your neighbor’s houses, why would we need appraisers and not
just inspectors confirming that the house was still standing?
Statistically, the larger the group you take you’re sampling
from, the more accurate your results. AND since you are the one
ultimately determining value and lending the money why would
there be any appreciation allowed beyond what you had determined
was an acceptable amount? Say 1-3% for flyover states and 3-5%
for the coast?" (Anyone willing to let the government control
the market for housing to this great a degree, step right up!)
The
big story yesterday was that another MI company has stopped
writing new commitments. “We are writing to inform you of the
very recent regulatory decisions that have impacted our ability
to write new commitments. Specifically, PMI Mortgage Insurance Co.
(“PMI”) and PMI Mortgage Assurance Co. (“PMAC”) have been
informed that they must cease writing new commitments for
insurance effective as of the close of business on August 19,
2011. PMI and PMAC may issue mortgage insurance policies
under pending commitments through the close of business on
September 16, 2011.” There was the usual language about “we will
support our customers’ ongoing policy servicing needs and loss
mitigation programs. PMI will maintain all systems, processes,
and contact points for policy servicing, loss mitigation, and
claims operations just as we do today.”
Freddie
Mac and Fannie Mae
wasted no time. "Effective immediately, we are suspending PMI
and its wholly-owned subsidiaries as approved mortgage insurers.
With this suspension, mortgages insured by PMI with note dates
before May 19, 2011, or after September 16, 2011, will no longer
be eligible for sale to Freddie Mac. To help manage your
pipeline, mortgages insured by PMI with note dates on or after
May 19, 2011, and on or before September 16, 2011, must be
delivered to Freddie Mac on or before December 30, 2011, whether
for borrower-paid or lender-paid insurance.”
Freddie reminded clients
that there are indeed other approved MI companies: http://www.freddiemac.com/sell/guide/exhibit10.pdf.
Investors
followed.
CitiBank quickly
spread the word to clients. "In order to meet the deadlines set
by PMI's regulator, Citi is requiring any loan insured by PMI be
purchased by Citi no later than September 2, 2011. Reminder:
Payments for any single premium MI policies must be submitted to
PMI immediately upon loan closing." U.S. Bank Home Mortgage
Wholesale Division wrote, “In-process loans, insured by
PMI with certificate dates on or before August 19th, 2011, will
be accepted for purchase under the following criteria: Existing
loans in your pipeline, with certificates issued by PMI, must be
closed, disbursed/funded by August 31st, 2011 and be delivered
and purchased by USBHM on or before September 9th, 2011. Loans
with PMI insurance certificates that do not close by the above
deadlines will not be accepted by USBHM until new MI insurance
is obtained from one of our other approved MI providers: MGIC, Radian, UG,
Genworth, and Essent.
Speaking
of UG, it sent news out to its clients that, "We have new
appraisal guidelines that reflect the new Uniform Appraisal
Dataset from Fannie Mae and Freddie Mac. We'll be modifying our
underwriting requirements guides to reflect these changes,
effective 9/1: http://www.ugcorp.com/news/announcements/CA2011-18_Uniform_Appraisal_Requirements.pdf.
Accenture
announced its acquisition of mortgage outsourcing provider
Zenta. The release said, “In a move that puts the global
consulting and outsourcing provider in the thick of the mortgage
origination business and the massive loss mitigation efforts
ongoing in the mortgage servicing industry.” Zenta has 3,700
employees provide business process outsourcing in mortgage
origination fulfillment, servicing loss mitigation, as well as
portfolio due diligence and management for investors.
The
deal prompted one industry vet to write to me, “Mainstream
origination firms are clamoring for better LOS technology, not
for BPO providers to take over their back office. The 'people
challenges' involved in end-to-end BPO are huge, especially in
purchase money transactions where sales compensation is at risk
and loan officers are loathe to disrupt trusted personal working
relationships with their processing team. Nor is there a magic
fountain of elastic capacity - when the demand switch flips and
everyone needs scarce talent at the same time, exactly how will
Accenture/Zenta instantly fill critical high skilled roles any
better than anyone else? And then there is there is the question
of who takes repurchase risk when the end-to-end process is
shared with a third party and the investor's claim cites a
tangled mix of defects whose trails cross organizational
boundaries? These challenges have ‘undone’ a slew of entrants to
the first mortgage end-to-end BPO space who believed that
superior technology held the answer.”
Last
week stock markets declined as the euro zone sovereign debt
crisis remains unresolved. (Germany is opposed to common
euro-denominated bonds despite pressure from the European
Commission and members of the European Union that see this as
the solution to the debt crisis.) The big problem with euro
bonds is that the European Union members do not have common
fiscal policies. The general consensus is that Europe must find
solutions for the current debt obligations before they can work
on how the Union will handle future obligations.
Over
in the U.S., of course, rates remain low. A major problem, of
course, is that current low interest rates are a result of
falling confidence in the economic outlook. It's cheaper than
ever to borrow, but that's because no one wants to borrow!
Current coupon (whatever that is these days) MBS prices ended
the day lower/worse by .125-.250 while 10-yr Notes were nearly
unchanged at 2.09%. News is limited again with only New Home
Sales for July coming out at 9AM CST, and a $35 billion 2-yr
note auction, and in the early going the 10-yr is at 2.14% and
MBS prices are worse a smidge.
A
tourist in a bar in Florida asks an Irishman sitting at the bar,
"Why do scuba divers always fall backwards off their boats?"
To which the Irishman replies: "If they fell forwards they'd
still be in the darned boat!”
If
you're interested, visit my twice-a-month blog at the STRATMOR
Group web site located at
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