Wednesday, July 27, 2011

July 27: Loan limit cut preparations trickling down; news from most major investors from BofA through ING to Wells

A loan agent sent me a joke yesterday: "What's the difference between the US

government and a subprime borrower? None - they borrow money that they can't

pay back in hopes that some inflated value will bail them out in the end."

But given our low rates, one analyst asked, "Has US government debt become a

safe haven for its own downgrade?"



One thing for sure is that US banks are holding on to more cash and locking

in longer-term financing as they brace themselves for the consequences of a

potential downgrade  of the US's triple A credit rating. The Financial Times

notes that if US government bonds lose their AAA rating, banks using them as

collateral may have to endure higher "haircuts" on the collateral,

potentially sparking a credit crunch especially in  the $3 trillion

repurchase, or "repo", market, on which large institutions rely  for

short-term funding.



Bank of America is not out of the woods yet. Recently six Federal Home Loan

banks have "launched a salvo" against Bank of America's proposed $8.5

billion mortgage  bondholder settlement, suggesting the payout may need to

be triple that amount.

 "Research reports used to determine the settlement figure were too

favorable to  B of A, used faulty estimates from the Charlotte, N.C., bank

and 'raise more questions than they answer.'" This reminds us that the

FHLB's don't all have to act together in matters such as this, and the six

(Boston, Chicago, Indianapolis, Pittsburgh,  San Francisco and Seattle) have

filed a separate claim. Others, such as the Federal Home Loan Bank of

Atlanta were part of the June settlement along with PIMCO and BlackRock.



Flagstar is not out of the woods yet, either. The holding company for

Flagstar Bank reported a 2nd quarter net loss of almost $75 million,

following a first quarter

 2011 net loss of almost $32 million, and a second quarter 2010 net loss of

$97 million. The loss is attributed primarily attributed to "legacy balance

sheet" issues.

Flagstar has ramped up its commercial lending this year, which has helped,

along  with selling $68 million in non-performing commercial real estate

assets. In the 2nd quarter "Mortgage rate-lock commitments increased $0.9

billion, or 16.8 percent, from prior quarter."



Moving from Michigan to Iowa, Wells Fargo will be undergoing some

mortgage-related changes in management. Cara Heiden, co-president of the

mortgage business, will be following Mark Oman (who runs mortgage and

consumer finance) into retirement.

 Mike Heid will become the sole president of Wells Fargo Home Mortgage, and

Avid  Modjtabai will head up the Consumer Lending Division (which includes

mortgage, home equity, and student loans). Promoting from within...



Anyone in compliance or quality control may want to participate in the next

monthly conference call/webinar of the California Mortgage Bankers

Association's Mortgage Quality and Compliance Committee (MQAC). Several

speakers will be discussing the  "Impact of New Fair Lending Oversight

Initiatives," and it's free tomorrow (Thursday) at 11AM PST. Contact Dustin

Hobbs for webinar login information at dustin@cmba.com

[mailto:dustin@cmba.com] although the teleconference portion can be heard by

dialing

1-800-351-6802 with verbal passcode 437841.



Regardless of whether you are in favor or not of extending the temporary

loan limits, investors from the top down are preparing for 10/1 when they

are scheduled to be  scaled back in many areas. (Freddie's page can be found

at  FreddieLoanLimits

[http://r20.rs6.net/tn.jsp?llr=zy6u9cdab&et=1106801640221&s=8721&e=001N8CsXS

7RtrpNy75josOneteCXUtWE8oCqkz66RrMcRS_UkAAda2yeHTj9eqMq2RFK2NxMcl85kdTC4Mu9B

LXU-bTm6nLKg5zJns9r-DUSxd0jlbIRmfUSby8YAUisiADq6-IzVUPcvcwrn55LTcKoQ==].)

 For Freddie, the expiration of the temporary maximum loan limits will

impact the sale of super conforming mortgages with note dates on or after

10/1. "Super conforming mortgages will be subject to the limits determined

according to the Housing and Economic Recovery Act of 2008 (HERA). Mortgages

with note dates on or after October 1, 2011 must have an original loan

amount equal to or less than the 2011 HERA limit for that county/#units

combination. The maximum allowable limit for a 1-unit property in the

highest cost counties (exclusive of those in AK, HI, GU and VI) will be

$625,500, with 2-4 units being higher." Freddie also reminded us that

"Congress might act on loan limit legislation again before October 1, 2011.

Should that occur we will provide you with further guidance."



This obviously trickles down. U.S. Bank told its brokers that, "The Super

Conforming Loan Limits for FHLMC/FNMA/FHA are due to expire on September 30.

From all indications, it is likely that the current limits will not be

extended and the new limits will be reduced not only to the absolute limit

(reduced from $729,250 to $625,500) but individual county limits as well.

Exact limits will not be known until sometime around the first week of

September..." USBHMWD will be taking several steps ahead of that, such as

putting a 9/30 deadline in place for any closings, disbursements, and file

deliveries. USB notes that for VA loans, however, "the maximum loan amounts

available through USBHM will not change however, the Veterans maximum

eligibility/entitlement available in Super Conforming counties is subject to

change." Check with USB for  details.



And it trickles down further. Out in California, for example, Mountain West

Financial told brokers of instituting funding cut off dates for

Conventional, FHA and VA maximum loan limits. "MWF will require that these

loans (under the temporary loan limit)  fund by September 23. For mortgage

loans with note dates after September 30th, revised limits will apply. The

maximum limit is $625,500 for a 1-unit Property in the continental United

States. General Loan Limits for 2011 will remain unchanged from the 2010

general loan limits. MWF will require that FHA and VA loans under the

current high cost limits to fund by August 31. FHA loan limits would likely

decline in 669 of the 3,334 counties or county equivalents that are eligible

for  FHA insurance."



Recently the commentary noted that Chase referenced a HUD bulletin

concerning the annual MIP change. As it turns out, the change in MIP was not

announced via a Mortgagee Letter but instead the change was made directly to

HUD TOTAL Scorecard and CHUMS.

I received a note, "Regarding the HUD/FHA MIP change, in HUD's defense they

did let the industry know during a 6/2 MBA industry conference call that the

changes  were coming." An astute reader noted, "We identified the change via

a difference between our LOS and FHA TOTAL Scorecard annual MIP values.

Loans with a loan terms

<15 years and LTV's <78% now reflect 0.00 in the Annual MIP returned from

TOTAL Scorecard. Additionally if the Correspondent checks the FHAConnection

Case Query  screen, they will see a 0.0 factor for this segment of loans.

The Correspondent  would use the TOTAL Scorecard findings and the

FHAConnection Case Query screen as their documentation. The Mortgagee Letter

is still pending from HUD."



Another wrote, "Regarding ML 2011-22: FHA's Mortgagee Letter 2011-22

Condominium  Approval Process for Single Family Housing was released

6/30/11, also affects Quality Control and Record Retention requirements for

some Lenders. Lenders who perform FHA Condo Project submissions under the

Direct Endorsement Lender Review and Approval Process (DELRAP) option will

need to implement a new addition to their FHA Quality Control Review

Procedures and Record Retention requirements. This ML requires a QC review

minimum of 10 percent of all project approval reviews and a 3 year record

retention period of all legal documents and other supporting & associated

documentation in connection with a DELRAP participant's review and approval

or denial of the condo project submission after the date of the last action

taken:  HUDML

[http://r20.rs6.net/tn.jsp?llr=zy6u9cdab&et=1106801640221&s=8721&e=001N8CsXS

7RtroPGlb7YdHm5vWtlld4K8MTIRSXoMQH9MWUPMzsiColtp71a8REZmAdB09LGJY4BjjlsUAYFs

MpIT93GPJrQSOFXdxNitJL0fwkqf6YhHHzST0Vba0waP9og3HtnpCQsO67wRwywHslfUkOF3pQq-

UVFNEcYxgtFQY=].



Bank of America recently notified its correspondent clients of a change in

the way they can view Residency Status and Documentation Requirements for

Conforming, FHA and VA loan programs (all in one section now) and its Rural

Housing guidelines now include that the borrower may be a Qualified Alien.

Clients should refer to USDA  Rural Housing Policy for eligibility.

GMAC continued to make pricing adjustments. This time correspondent clients

learned that, starting last Thursday, GMAC will be adding two rate

adjustments to the LPMI

products: +.250 rate adjustment on FICO >=700 and loan amounts >$417,000 and

<= $625,500, and +.500 rate adjustment on FICO >=700 and loan amounts

>$625,500 and  <= $729,750.

SunTrust revised their tradeline underwriting policy. ("SunTrust Mortgage

considers borrowers who have too few reported tradelines or insufficient

trade histories on a case-by-case basis.  Strong compensating factors must

exist.  We require a second tier review by a SunTrust Mortgage Underwriting

Team Lead or Underwriting Manager.") It also refined its appraisal policy

("SunTrust Mortgage, Inc. revised the Appraisal Guidelines to specify review

appraisals as field review appraisals.  We do not allow the use of desk

review appraisals.") and published additional guidance regarding  permanent

resident alien green card expiration dates and acceptable documentation for

clients with a green card expiring within six months after closing.

ING reminded brokers that, "pursuant to your company's executed Broker

Agreement, in the event that the Broker solicits the refinance of a Loan

previously funded by ING within one hundred eighty (180) days of the funding

date by ING, Broker shall repay ING, within (30) days, any premium or

similar amounts paid to broker by ING at the time of original purchase

and/or funding of the Loan." To avoid recapture  do not submit a refinance

of a loan previously funded by ING Mortgage within 180 days of the funded

date."



Yesterday we had the S&P/Case-Shiller numbers: down from a year ago, up from

the  previous month. The index for 20 cities fell 4.5% from May 2010.

Nineteen of the

20 cities in the index showed a year-over- year decline, led by a 12% plunge

in Minneapolis. Washington showed the only increase, up 1.3% from May 2010.

Month over month, the 10- and 20-City Composites were up 1.1% and 1.0%,

respectively, in May over April. New Home Sales decreased 1% to a 312,000

annual pace in June, but the median sales price increased 7.2% to $235,200

from June 2010, and the average sales price was $269,000. (We have about a

6.3 month supply at the current sales rate.) Lastly, the Conference Board

Consumer Confidence Index improved slightly in July  to 59.5, up from 57.6

in June.



What did all that do to rates? Not much, really - the debt issue is

impacting the stock and bond markets more than weekly or monthly economic

news. European problems gave us a flight to quality bid, and now we have

speculation that a continued deadlock on the U.S. debt limit will slow

economic growth. The 10-yr closed at 2.95%, and  MBS prices gained between

.125-.250, depending on coupon. "Meanwhile, mortgage banker supply was

uneventful at around $1 billion."



This morning we learned that mortgage apps dropped last week by 5%, with

refi's down 5.5% and purchases down almost 4%. Refi's still account for

almost 70% of new business. We also found out that Durable Goods were -2.1%

for June (a volatile number) and although there are several ways to slice it

the Durable Goods number continues to point to a slow economy. Later we have

the Fed's Beige Book (11AM PST) and a

$35 billion 5-yr note auction. The 10-yr is nearly unchanged at 2.97%, as

are MBS prices.



Some humor for the kids:



Two peanuts walk into a bar. One was asalted.

A jumper cable walks into a bar. The barman says "I'll serve you, but don t

start anything."

A sandwich walks into a bar. The barman says, "Sorry we don't serve food in

here."



A dyslexic man walks into a bra.

A man walks into a bar with a slab of asphalt under his arm and says: "A

beer please, and one for the road."



Two aerials meet on a roof, fall in love get married. The ceremony wasn't

much but the reception was great.



Two cannibals are eating a clown. One says to the other: "Does this taste

funny to you?"



A guy walks into the psychiatrist wearing only Glad Wrap shorts. The shrink

says, "Well, I can clearly see you're nuts."



If you're interested, visit my twice-a-month blog at the STRATMOR Group web

site  located at www.stratmorgroup.com

[http://r20.rs6.net/tn.jsp?llr=zy6u9cdab&et=1106435366068&s=4179&e=001SVt-lj

bp53436QjxD9vbwURtIPPjV05jEcEKyBN3SjS2forXe0C_foO8RjEV-Uye0N7Z_Sh1il0SRXPx6P

jQauayNXQjni-Hc9Sseu-hhZcR1ujeZyAEpw==]

. The current blog takes a look at early actions taken by the new CFPB and

the political situation affecting it. 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.



Rob   (Check out


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721&ts=S0648&p=http%3A%2F%2Fwww.thebasispoint.com%2Fcategory%2Fdaily-basis].

For archived commentaries, go to www.robchrisman.com

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Copyright 2011 Rob Chrisman.  All rights reserved. Occasional paid notices

do appear.

This report or any portion hereof may not be reprinted, sold or

redistributed without the written consent of Rob Chrisman.)

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