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Dec. 8, 2011: Mortgage Ops job; Lending to borrowers with negative equity: spotlight on the FHA's Negative Equity Program
Rob Chrisman
If
you made a Christmas wreath out of $100 bills would you have
Areath-a Franklins?
I have been retained by a very well-capitalized mortgage bank to
assist in its search for
a Senior Regional
Operations Manager in Sacramento, CA. It is a national
lender with a portfolio lending appetite - company-wide
production is in excess of $5 billion through its wholesale,
correspondent, retail, and direct lending channels. The ideal
candidate will provide "leadership of the continued growth,
development, efficiency, and quality of the regional operations
center to support all wholesale and correspondent operations out
of assigned region, implement operational strategy and planning
execution in order to achieve operational business goals, and
should have a high core competency of understanding and
practical applied knowledge of underwriting, closing, funding,
and overall wholesale and correspondent operations processes and
procedures. Experience managing a mortgage operations center,
national strategic leadership experience preferred." Please send
resumes to me at rchrisman@robchrisman.com.
The Federal Reserve, the FDIC, and the OCC want your input on
some proposed rulemaking (NPR) that focuses on “the agencies'
market risk capital rules for banking organizations with
significant trading activities. The amended NPR includes
alternative standards of creditworthiness to be used in place of
credit ratings to determine
the capital requirements for certain debt and securitization
positions covered by the market risk capital rules. The
proposed creditworthiness standards include the use of country
risk classifications published by the Organization for Economic
Cooperation and Development for sovereign positions,
company-specific financial information and stock market
volatility for corporate debt positions, and a supervisory
formula for securitization positions.” Any time one combines
Basel III with Dodd-Frank and several government agencies, it
can become a little muddled: http://www.fdic.gov/news/news/press/2011/pr11189.html.
Agencies
are indeed trying to clarify their supervisory and enforcement
responsibilities for Federal Consumer Financial Laws. Remember
(who can forget) that Dodd-Frank
provides the CFPB with exclusive supervisory and primary
enforcement authority over "Large Institutions," defined as
institutions with total assets exceeding $10 billion. The
prudential regulators retain supervisory and enforcement
authority over their respective institutions falling under that
threshold. But the devil is in the details: the Dodd-Frank Act
does not specify how or when to calculate total assets for
purposes of applying the threshold. A copy of the joint
statement is available at http://www.federalreserve.gov/newsevents/press/bcreg/bcreg20111117a1.pdf.
Lending
to underwater borrowers, short sales, and foreclosures are a
sign of the times.
(When a borrower can come back after one of these is discussed
at
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