Sep. 20, 2011: Changes in g-fees, MI levels, and risk pricing from F&F? Correspondent lender rankings; improving commercial RE?
Rob Chrisman
It
used to be that people who walked down the street arguing with
nobody there were deemed "crazy". When cellphones first got
overly popular, my mother suggested that dead ones be issued to
all who wanted them, so that those with those forms of mental
issues could achieve social acceptance. It appears that that
happened, and in many cities the area is swarming with them. My
cousin suggested an idea for a TV game show, "Bluetooth or
Crazy?" The contestants are shown a brief clip of someone on
the street apparently talking to themselves in an animated
manner, taken from the non-headset side, and then have to guess
which it is, Bluetooth or crazy?
Residential and commercial real estate are often loosely tied
together, although commercial real is usually much more of a
“numbers game.” Capitalization rates have been found to be good
indicators of expected returns in commercial properties, and the
SF Fed points out that recent
declines in these cap rates appear to be signaling a
commercial real estate rebound, indicating improved
investor expectations of price growth in the market. It is good
to hear, and I hope that they’re correct: http://www.frbsf.org/publications/economics/letter/2011/el2011-29.html.
For
those out there rooting for the non-agency market to come
roaring back, there is a step in the right direction. Pricing engine Optimal
Blue has released Redwood Trust's Jumbo Fixed and ARM products.
Redwood has seen a solid increase in their number of clients,
percentage-wise, in the last year, and with good reason. At this
point Redwood Trust appears to be the only issuer of new
home-loan securities without government backing in quite some
time, and last week Fitch announced it will be rating a Redwood
pool ($375 million of jumbo mortgages, average balance of $793k,
80% from First Republic Bank & PHH).
On
the agency side, investors were buzzing yesterday about a speech
given by the Acting Director of the FHFA, Edward Demarco. There
is consideration being given to loosening guidelines or reducing
fees in conjunction with an expanded HARP offering – but HARP is not a mass
refinancing plan, although one can expect an increase in
guarantee fees. “Loan level price adjustments, representations
and warranties, valuation requirements, and portability of
mortgage insurance coverage are among the matters being
considered.” But, “It ought to be clear to everyone at this
point that the Enterprises will not be able to earn their way
back to a condition that allows them to emerge from
conservatorship.”
There
is a lot of conjecture at this point what this all means. If the
guarantee fees historically charged by Fannie & Freddie were
too low, relative to where they would have been in
non-government-backed world, then they will increase. (As a
reminder, g-fees are
charged to lenders for bundling, servicing, selling and
reporting MBS to investors, along with protecting against
credit-related losses in the mortgage portfolio.) “Private
firms would likely target a higher rate of return than the
enterprises and the market would demand higher levels of
capital,” DeMarco said. “I would anticipate that the enterprises
will continue the gradual process of increasing guarantee fees.”
Demarco also proposed risk-based pricing across more product
types and characteristics, limited geographic pricing, and the
elimination of volume discount of g-fees to lenders.
So
increasing the g-fees is in the cards. So is reducing cross
subsidization across products type and characteristics.
This has the potential to hurt weaker credit borrowers through
higher pricing – but, frankly, isn’t that the way much of
lending works? One can
also expect to see differential pricing across geographies to
better account for risk, local laws, foreclosure timelines,
etc. (This would indicate that judicial states with
extended timelines - such as NY, NJ and FL - may see higher fees
compared with non-judicial states such as CA.) We could also see
an increase in the amount of MI, perhaps moving the MI
requirement threshold below the current 80% LTV, although
at this point, asking the MI companies to take on additional
credit & financial risk is an issue.
I
received a few thoughtful comments about, surprise!,
compensation. "It is not surprising that the reader who wrote he
would earn the same at the ‘large lender’ with either comp plan
because the comp plan is written to allow banks to continue
paying their originators basically the way they always have. The issue is how it
radically changes the way originators at broker shops are
paid, forcing brokering originators to be paid as bank
employees. The differences in originator compensation
between bank and broker are primarily due to the originator at a
broker shop being much more involved with the entire loan
process than an originator at a bank. There are many other
problems with the comp rule, but here are four more:
“There is no data documenting the need for the originator comp
rule. Nor is there any data showing it will provide any benefit
or that it won’t have any negative consequences. There were and
are maximum revenue laws in place that are already more limiting
of brokers than lenders and banks. The comp rule is a poorly
conceived knee jerk reaction to events which had nothing to do
with compensation.
“The comp rule limits the free market ability of brokers to
compete against banks. Brokers used to account for nearly 70%
of all originations. Now that figure is down to about 9%. This
shows just how effective this (and other) legislation has been
in eliminating the broker’s ability to deliver benefit to
consumers - to the benefit of banks and the detriment of
consumers. It is government imposed pricing inflexibility
without it ‘technically’ being price fixing.
“The
comp rule wrongly assumes all borrower scenarios are created
equally. They are not. Many borrowers contact a broker after
they have been denied at a bank. It's like telling a housing
contractor they can only earn x% of the materials used to
replace a roof, regardless of how many floors high the roof is,
it's pitch, or its size. The pricing criteria are completely
ignored. How about legislation that mandates retailers sell
every product at the same margin? Or car dealers sell every car
at the same margin? Or restaurants sell every meal at the same
margin. It is the same with loans, they are all different.
This legislation, like HVCC – ‘Appraiser Independence’, hardly
seems legal.
“The comp rule wrongly treats revenue as a determinant of
whether a consumer is getting a ‘good deal’. It ignores that
wholesale lenders provide a range of compensation for the same
rate, depending on borrower scenario’s or the strictness of
their underwriting. A broker can use the ‘easy’ lender with a
higher rate instead of using the ‘hard to approve’ lender who
has the lower rate and earn the same, but the consumer does not
benefit. If the broker is willing to use the ‘hard to approve’
low rate lender, he should be compensated for the additional
work while at the same time being able to deliver more favorable
terms to consumers.”
For the second quarter,
who were the top correspondent lenders/investors? In order
of dollar volume, Wells Fargo, BofA, Chase, Ally/ResCap (GMAC),
CitiMortgage, Flagstar, PHH Mortgage, U.S. Bank Home Mortgage,
BB&T, Franklin American, SunTrust, Hudson City Savings Bank,
NYCB/AmTrust, Provident Funding, MetLife Home Loans, Astoria,
HSBC, M & T Mortgage, Nationwide Advantage Mortgage,
Crescent Mortgage, EverBank Mortgage, Regions Mortgage, Fifth
Third Mortgage, Colonial Savings, Midland Mortgage, Cimarron
Mortgage, and Stearns Lending, per the National Mortgage News.
"Very
little
has changed in terms of housing market conditions so far this
year," said NAHB Chairman Bob Nielsen upon the release
(downward) of the NAHB/Wells Fargo Housing Market Index. Well,
that pretty much sums it up, which explains why builder
confidence is not going ape. "Builders continue to confront the
same challenges in accessing construction credit, obtaining
accurate appraisal values for new homes, and competing against
foreclosed properties that they have seen for some time. Beyond
this, both builder and consumer confidence took a hit in recent
weeks with the market disruptions caused by the S&P
downgrade and congressional gridlock on the budget deficit."
Yesterday,
as
one trader noted, “Another day and still nothing progressively
notable has come from the EU regarding Greece.” Stocks worsened
and Treasuries rallied, although they don’t always move in
opposite directions. U.S. 10-year notes in particular surged
about 1.125 in price with the yield declining through 2.0% to
1.94%. But between the higher prices, EU uncertainty, looming
FOMC meeting and government refi worries, MBS investors had lots
of reasons to not get too involved although MBS prices closed
higher by over 1/2 to nearly 3/4 of a point on 30-year 4’s down
to 3.5’s.
But
outside of EU headlines, with a little progress in Greece
seeming to temporarily outweigh S&P’s downgrade of Italy,
today’s calendar is pretty light. The Fed starts its meeting.
And we’ve had Housing Starts and Building Permits. Permits came
in at 620k, up slightly, although Starts were down 5%. The news
didn’t move rates too much, and the 10-yr is around 1.98%
and MBS prices are worse by about .125.