Jun. 13, 2012: Wells' market share target (?) & Streamline change; CFPB's view of mortgage brokers; the MBA & 203(k)'s
Rob Chrisman
Industry
experts believe that one of the several reasons Countrywide fell
was because of their quest for market share for its own sake,
rather than have quality and service drive the market share.
Conversely, Wells' market share seems to have come about through
"always being there" with steady products, pricing, and service
- until now? It seems like some portion of Wells Fargo’s
management or retail personnel is now shooting for market
share: http://www.sfgate.com/cgi-bin/article.cgi?f/c/a/2012/06/12/BU301P0LP7.DTL.
Although I doubt if this the "official" company goal, dressed up
like cowboys? How Alt-A era!
The
government does what it can to help borrowers, some who perhaps
should not been allowed to borrow money in the first place:
encouraging loan modifications, FHA Streamlines, HARP, and HARP
2.0 quickly come to mind. But as we’ve all found out, many times
the government can’t “make” an investor follow a program, and
investors often add overlays or restrictions when their own
risk position is compromised.
Regardless,
Wells Fargo turned some heads yesterday with its announcement
that “Wells Fargo Funding will no longer accept non-Wells
Fargo serviced FHA streamline refinance transactions.
Wells Fargo is committed to helping borrowers nationwide with
their mortgage financing needs, and this decision will help us
accomplish that by focusing on borrowers in our existing
servicing portfolio. This policy applies to each of our
origination channels across Wells Fargo Home Mortgage.” For Best
Effort Locks, relocks, and renegotiations, it takes effect on
and after June 19, and Mandatory Commitments must be delivered
on or before July 31, 2012. “This restriction does not apply to
Wells Fargo serviced loans.” And “Wells Fargo Funding will
continue to purchase FHA Regular Credit Qualifying Refinances
(includes Rate and Term and Cash out Refinances) provided they
meet FHA’s definition of a Regular Credit Qualifying Refinance
with an appraisal. This includes both non-Wells Fargo serviced
loans and Wells Fargo serviced loans.”
As
most underwriters know, Wells offered traditional streamline
refi’s without appraisals (with a few exceptions) down to 640
FICO up until this announcement regardless of servicer. Most
other investors, if they allow these at all for loans they
didn't service, require an appraisal. So it would seem that
Wells joined other investors, from a risk perspective.
There might be capacity issues, since starting yesterday
borrowers with loans endorsed prior to May 31, 2009 can take
advantage of reduced MIP on a streamlined loan. Throw this in
with a low rate environment, and here we have it.
Earlier
this week I told a group of lenders in Arizona that the stated
mission of the CFPB is great from a public relations
perspective, but if not controlled can drive our industry into a
hole. One person reminded me that, “The good parasite doesn't
kill its host,” not that the CFPB is a parasite – but you get
the idea. But one can certainly obtain a sense of the CFPB’s
thoughts from remarks by Raj Date, Deputy Director of the CFPB,
to some bankers in Florida this week. Date reminded us that,
“The Dodd-Frank Act was passed in response to the crisis and
created the CFPB as a single point of accountability for
consumer financial protection.” That is a good thing. But Date
goes on to say, “The Bureau can, for the first time, extend
federal supervision to non-depositories. (Editor’s note: any company
who thinks that they can’t be audited by the CFPB is
incorrect. And you’d better have every rate sheet from every
day, and every rate/price calculation, ready for them.)
This is a critical advantage. After all, if you think back to
the most problematic vintages of mortgages during the bubble —
for example, subprime and Alt A mortgages between 2005 and 2007
— most of those problematic mortgages were originated not by
supervised banks, but by mortgage brokers and finance companies
who then sold those loans into capital market execution on Wall
Street. The results, needless to say, were not great.”
Date
goes on. “Let me give you an example from the mortgage bubble:
the yield-spread premium. Too often it was the case that
mortgage brokers were paid more to give borrowers a worse deal.
If a borrower could qualify for a loan at, say, 6 percent, a
broker might juice that rate from 6 percent up to 8 percent. As
a result, the most important, most visible person in the
mortgage process for many borrowers – the mortgage broker – had
a financial stake that was confusingly and perversely in direct
opposition to the interest of the consumer himself. If people
are paid to treat customers poorly, it shouldn’t be surprising
when they do.” The entire speech can be read here: http://www.consumerfinance.gov/speeches/remarks-by-raj-date-to-the-american-bankers-association-conference/.
It
is rumored that Marc Savitt, president of the National
Association of Independent Housing Professionals (NAIHP)
called Date’s comments “outrageous” and that the NAIHP is
calling for Date’s resignation, per MReport. “The banks
approved these loans, not the brokers.” While Date speaks of
‘transparency, fairness, and proper financial incentives,’
Savitt believes Date’s bias makes him unfit for his role.” When
I, however, visit the NAIHP website and try to find news of
this, up pops something from March of 2011. Maybe I just
couldn’t see it: http://www.naihp.org/inthenews.
But
for something that can be found on a website, the Mortgage
Bankers Association (MBA) has called on the U.S. Department of
Housing and Urban Development (HUD) to cease its moratorium
on allowing investors to participate in the department’s
Section 203(k) rehabilitation loan program. The moratorium
was put in place in the mid-1990’s due to fraud and waste which,
per the MBA, have been taken care of. "The MBA believes that
there would be significant benefits from allowing individual
investors to participate in the 203(k) program." Read the
release: http://www.mbaa.org/NewsandMedia/PressCenter/80974.htm.
How
about some relatively recent Wells updates, besides the
Wells news at the top? As always, it is best to read the actual
bulletin.
Wells
Fargo
Wholesale has introduced new tools, including
an FAQ section and a reference document that outlines
definitions, eligibility, and documentation requirements, to
assist in completing loan packages that involve trusts. These
can be found under Client Tools on the Broker’s First® website.
Effective immediately, Wells has reduced and aligned
simultaneous home equity fixed rates in all states for the HELOC
with Fixed Rate Advance Options, with the reductions ranging
from 0.75% to 0.25% depending on the state. One- to three-year
Interest-Only Fixed Rate Advances now start at 4.975%, and
amortized fixed rate pricing starts at 5.375%.
For those who want to cancel an existing FHA Case Number
to take advantage of the FHA’s reduction of the MI premium for
Streamline refinances, Wells has outlined the necessary
process. The endorsement date of the loan being refinanced and
the eligibility should first be determined and the original Case
Number validated. The endorsement/insured date listed on the
HUD-1 Settlement Statement or Note should then be confirmed by
emailing the Wells support team at websupport@wellsfargo.com
or calling (866)661-8025. If the loan is eligible, this should
be discussed with the borrower; if the borrower opts to move
forward, the new Case Number should not be ordered until June
11th at the earliest. For loans that have been submitted to
Wells that are in process and for which the Case Number has been
ordered and assigned, the Wells web support team should be
contacted using the FHA Case Number Cancellation Request form.
When the Case Number has been assigned, the underwriter should
be notified and the new Case Number assignment print-out
submitted along with the file. Delays are likely due to the
expected high volume of requests.
Wholesale clients are reminded that the “Your Loan Options”
section of the MBFD should be completed fully and accurately
before submitting the loan to Wells Fargo. To properly fill out
this section, the loan with the lowest interest rate should be
disclosed as the first option and the loan with the lowest
dollar amount as the third option. In order to avoid steering
the borrower to a specific loan, the options must include the
loan with the lowest interest rate, the lowest rate without
risky features, and the lowest dollar amount of points and
origination fees on the first three lines, which means that the
fourth line cannot be lower than the rates and dollar amounts
shown above.
Beginning June 15th, Wells Wholesale will accept only 2010
and 2011 tax returns. Tax returns from 2009, however, may
still be requested by the underwriter. Let’s hope they all agree
with the 4506! And June 18th marks Bunker Hill Day in
Suffolk County, MA, and will be excluded by Wells Wholesale in
the business day count for Right of Rescission timing. Very
exciting!
On a relative basis, the markets were pretty quiet Tuesday.
MBS sales volumes picked up a little, but with little news from
Europe and nothing in the United States, aside from a $24
billion 3-yr note auction, the market decided it was time to
drop a little. MBS prices were down/worse slightly, but not as
much as the 10-yr T-note which worsened by about .5 in price and
closed at 1.66%. But keep in mind that nothing in Europe has
been resolved, the Greeks will hold yet another election Sunday,
QE3 is still an option, and the FOMC will release its monetary
policy statement next Wednesday.
As
for the early going today, we had the MBA’s application index
for last week showing a big jump in apps (+18%!) and
hitting their highest level since 2009. Refi’s were +19% and
purchases were up about 13%. Refi’s are still hovering around
79% of overall applications. We also had the Producer Price
Index for May, -1.0%, and Retail Sales -.2% following April’s
-.2%. Producer Prices dropped more than expected, while Retail
Sales, representing about 2/3 of our GDP, came in about as
expected. The Treasury will auction $21 billion in 10-year notes
at 1PM EST today. Currently MBS prices are roughly unchanged
from Tuesday’s close and the 10-yr is at 1.67%.
The 5 toughest questions for men. (Part 4 of 5; guaranteed to
get me into hot water, but I will gladly print the opposing view
if someone sends it to me.)
1. What are you thinking about?
2. Do you love me?
3. Do I look fat?
4. Do you think she is prettier than me?
5. What would you do if I died?
What makes these questions so difficult is that each one is
guaranteed to explode into a major argument if the man answers
incorrectly (i.e. tells the truth). Therefore, as a public
service, each question is analyzed below, along with possible
responses.
Question # 4: Do you think she's prettier than me?
Once again, the proper response is always: "Of course not!"
Incorrect responses include:
a. Yes, but you have a better personality.
b. Not prettier, but definitely thinner.
c. Not as pretty as you when you were her age.
d. Define “pretty.”
e. Could you repeat the question? I was just thinking about how
I would spend the insurance money if you died.
If
you're interested, visit my twice-a-month blog at the STRATMOR
Group web site located at www.stratmorgroup.com .
The current blog discusses the issue of the Freddie Mac &
Bank of America buybacks, and its potential impact on the
industry. If you have both the time and inclination, make a
comment on what I have written, or on other comments so that
folks can learn what's going on out there from the other
readers.