“I
would be moody too if I was standard and poor.” I don’t know how
old that pun is, but many in the industry continue to wait for
the rating agencies (those that had the lion’s share of the
business 6 years ago) to take more of the blame for the credit
crisis. There are newer firms, however, releasing information to
help us better understand how residential mortgage-backed
securities perform – or don’t perform – a question that I am
sometimes asked. In a piece done last year by Kroll Bond Ratings
(known more for commercial MBS rating), the author identifies
the following independent
variables as being highly correlated to the performance of a
RMBS: FICO, documentation, occupancy, loan purpose,
margin, adjusted CLTV, refinance incentive, age, prepayment
penalty, and loan balance. For more visit www.krollbondratings.com.
Redwood
Trust
doesn’t have a monopoly on jumbo deals. Recently Two Harbors Investment
Corp. and its partner Barclays Bank agreed on a May 17
deadline for the issuance of a new residential mortgage-backed
securities deal, according to a filing with the SEC. The two
firms said in May they would be targeting a $250 million RMBS
deal using a warehouse line to gather the jumbo mortgages.
Assuming this goes through, however, it would only be the fourth
private-label RMBS offering since 2007 – the other three were done
by Redwood. Reportedly should Two Harbors, the seller in
its deal, fail to deliver the security before May 17, Barclays,
which is the initial purchaser, would agree to buy the assets.
Two Harbors must obtain an AAA rating on the security from at
least one ratings agency. Don’t
forget about possible risk retention rules – if they exist
by then!
Hey,
did you hear the big rumor? Me neither. But some rumor pushed
Bank of America's stock to surge the most in two months of
trading ("skyrocketing” to $6.31 per share) amid speculation
that "the U.S. may introduce a new mortgage refinancing
program." I'm always the last to hear this stuff, and didn't
hear the rumor until after an Obama administration official who
asked for anonymity denied speculation that the White House is
considering a trillion-dollar plan to refinance home loans.
Doubt it.
The
VA upped its appraisal requirements, and lenders such as
Guild, Home Savings, and everyone else is following suit.
The VA released VA Circular 26-11-21, which states that
effective immediately, “VA requires Staff Appraisal Reviewers
(SARs) to issue the Notice of Value (NOV) at the appraised value
reflected in the appraisal. Furthermore, SARs are no longer
permitted to issue an NOV at a value other than that reflected
on the VA appraisal. SARs must continue to contact the appraiser
to resolve errors, omissions and discrepancies discovered when
reviewing the appraisal. In the event the appraiser’s revisions
result in a changed value, the SAR must re-issue the NOV at the
new appraised value reflected on the revised appraisal. Only VA
staff or the original appraiser is permitted to make adjustments
to the appraised value.” In HSOA’s case, “On a limited basis,
when significant disputes related to property value arise, HSOA
will submit the VA appraisal to VA staff for their review and
possible value adjustment.” The impact of this VA policy change
is that value resolution may take longer if the SAR (HSOA’s
appraisal review underwriter) disagrees with the appraisal’s
content or conclusion.
But
wait – there’s more! Going forward for all appraisals, in
addition to VA’s current exterior photograph requirements, VA appraisers must provide
photographs of the following rooms and/or property conditions:
kitchen (mine’s a mess!), all bathrooms (don’t ask), main living
area (fair), and all physical deterioration, if applicable (you
bet it is), along with examples of recent updates, such as
restoration, remodeling and renovation, if applicable (do
particle board-on-cinder block bookshelves count?).
“As
the new Director of the
CFPB, and as someone who has been helping to build the
Bureau for about a year now, I can tell you it's an
extraordinary privilege to work on behalf of American consumers.
Consumers like you. Tell your story: https://help.consumerfinance.gov/app/tellyourstory.”
So wrote Richard Cordray.
Some
in the mortgage industry told theirs. Mike Hillman wrote,
“Here's my story. I have worked at all levels of the mortgage
industry for the past 27 years and, almost without exception,
every single regulation you sophomorons in Washington have
implemented to ‘protect the consumer’ has stood in the way of
what the vast majority of us in the Industry can offer by way of
products and services to the vast majority of those in need of
real estate financial services. You should take a lesson from
the medical profession, ‘First Do No Harm.’” And on his blog LO
Julian Hebron provided an open letter on his thoughts: http://thebasispoint.com/2012/01/05/open-letter-to-new-cfpb-head-richard-cordray/.
Wednesday
the
commentary discussed Pacific
Union Financial and its "minimal overlay FHA and FNMA
product (scores to 560,
no DTI limitations with approve eligible, flips over 20%, 5-10
NOO, etc.) and they recently released a standard FHA product
(that still allows high DTI and flips with over 20%
appreciation)." This set
off a debate. “I’m disappointed that you would highlight a
program like this that to me is a throwback to subprime
lending. Have we all not learned anything from the lending
crisis? Sure FHA still technically allows this type of product
to be originated but with that said don’t we all recognize that
granting credit to a borrower with a combination of a 560 FICO
and limited down payment or a combination of a high debt ratio
and limited down payment is a recipe for disaster? Low FICO
loans combined with low down payments results in a ridiculously
high percentage of foreclosure as do loans with high FICO’s and
limited down payments (which then culminates in bad press for
our industry). And people wonder why the legislature is trying
to regulate “an ability to re-pay” standard?”
On
the flip side, “The industry seems to have given up on doing
loans that ‘make sense.’ Would you deny credit to someone who
may have been in the hospital and missed some bills? Pac Union’s
lower FICO program has less than 1% delinquency on the 60 day
plus metric. This is actually public knowledge through its
servicing numbers on Neighborhood Watch.” One employee wrote, “There are several
compensating factors in underwriting. For example, all of
these loans require approve/eligible from DU or Total Scorecard
so the scores in the 500’s don’t seem to make it very far unless
they are a low LTV. The highest LTV I have seen with a 560’s
score has been 47. Our average score is 652 so some sellers are
dipping into the lower scores while others are staying in the
higher scores but may have a higher DTI or it could be a flip.
Our wholesale channel had a compare ratio of 56% last I
checked.”
U.S.
Bank Home Mortgage
(wholesale) announced its pricing move to cover the costs due to
the mandatory increase in guarantee fees required by FHFA.
“Locks taken prior to 1/3 that do not close and fund by 2/17 and
that require an extension, the following new extension fees will
apply: 20/25/30 year term – current lock extension fee schedule
plus 40 basis points, 10/15 year or less term – current lock
extension fee schedule plus 35 basis points. Our standard lock
extension fee schedule will apply to any locks taken on or after
1/3.” For delivery fees, “Locks taken prior to 1/3 that are not
received for delivery to USBHM by 2/17 that do not meet our good
delivery requirements (deficiencies cleared within 7 calendar
days of notice) are subject to the following late clearing of
deficiency fees AND new fees: 25/30 year term – current lock
extension fee plus deficiency fee plus 40 basis points, 15 year
or less term – current lock extension fee plus deficiency fee
plus 35 basis points. Again, Seller will have the greater of the
expiration date or 7 calendar days from notification to clear
funding deficiencies without any pricing penalty.”
Freddie
Mac
sent word that effective for Freddie Mac settlement dates on or
after January 5, 2012, “we are eliminating the minimum Indicator
Score requirement of 620 for Relief Refinance Mortgages – Same
Servicer with LTV ratios less than or equal to 80 percent,
provided the principal and interest payment does not increase by
more than 20 percent, and eliminating the minimum Indicator
Score requirement of 620 for Relief Refinance Mortgages – Same
Servicer with LTV ratios less than or equal to 80 percent,
provided the principal and interest payment does not increase by
more than 20 percent. Effective for Freddie Mac settlement dates
on or after January 5, 2012, we are eliminating the maximum
total LTV (TLTV) and Home Equity Line of Credit TLTV (HTLTV)
ratio requirement of 105 percent for Freddie Mac Relief
Refinance Mortgages – Same Servicer and Relief Refinance
Mortgages – Open Access with LTV ratios of less than or equal to
80 percent.” It is best to read the full bulletin at http://www.freddiemac.com/sell/guide/bulletins/pdf/bll1201.pdf.
The
markets have been behaving themselves – certainly no one is
complaining about rates. (One little tempest in a teapot has
been the underperformance of Ginnie Mae securities in recent
weeks, impacting FHA & VA prices. But if you think about it,
those prices had run up in recent months – besides, what foreign
investor doesn’t want some type of explicit guarantee with some
of these securities?) Yesterday investors couldn't decide which
side of the risk equation they wanted to be on: ADP Employment
and Initial Claims were better than expected, but Europe is
still a pain in the neck. 10-year T-notes closed virtually
unchanged at 1.99%, and in mortgage-land originator selling
remained limited to the $1 billion area which isn't enough to
satisfy the Fed let alone other investors so prices improved
slightly.
This
morning
we’ve had the employment numbers. Non-farm Payroll was +200k,
much stronger than expected on widespread job growth, although
November’s number was revised downward from +120k to +100k
(October’s was revised slightly higher). Are folks just dropping
out of the hunt for jobs, which impacts the number? The
unemployment rate was 8.5%, down from November’s 8.7%, and the
average workweek rose slightly. Prior to the numbers the
T-note was at 2.01%, and it moved to 2.02% - not a big move,
and mortgage prices appear nearly unchanged from Thursday
afternoon.
A woman gets on a bus with her baby. The bus driver says:
“That's the ugliest baby that I've ever seen. Ugh!”
The woman goes to the rear of the bus and sits down, fuming.
She says to a man next to her: “The driver just insulted me!”
The man says: “You go right up there and tell him off – go
ahead, I'll hold your monkey for you.”
If you're interested, visit my twice-a-month blog at the
STRATMOR Group web site located at