Thursday, October 6, 2011

October 6: Production jobs; FHA Streamline issues; MERS victory; more on NMLS training; investors suspending programs & limiting AMC's

Production jobs come and go. On one side, Kinecta Federal Credit Union is

continuing to grow its business and is hiring Retail Mortgage Loan

Consultants and Sales Associates throughout Southern California. It is also

growing its wholesale lending with AE  positions open in California, Kansas

Iowa, Utah, Idaho and the Northeast US.  "Kinecta FCU is one of the nation's

leading Credit Unions, with more than $3.5 billion in  assets and serving

over 220,000 member-owners across the country.  Kinecta offers a competitive

compensation and benefits package in addition to a dynamic culture  and a

large product line." If you know of someone who might be interested, they

should contact Sue Ann Smith at ssmith@kinecta.org




On the other side, Perhaps Kinecta can pick up some BofA folks. Bank of

America this week made the decision to exit retail lending in six low volume

states including Alabama, Alaska, Montana, Nebraska, Wisconsin, and Wyoming,

per the National Mortgage News. I bet if Ken Lewis, or Brian Moynihan, could

turn back time, they'd do it.

 "An inspector general for HUD has recommended that Bank of America face

fraud charges relating to faulty borrowing data submitted to the agency in

connection with its  Countrywide unit. In his words "Countrywide did not

properly verify, analyze, or support borrowers' employment and income,

source of funds to close, liabilities and credit information." And isn't

that the basic problem, summed up in one little sentence?



In the bulletin Bank of America also tweaked its FHA Streamline Refinance

underwriting:

"At time of application, at least 12 full months must have passed since the

first payment due date of the mortgage being refinanced." It is indicative

of an apparent trend in the industry to question the long-term viability of

the program, to wonder what future class-action lawsuits might be ahead for

companies that specialize in them, and to think out loud about FHA claim

denials and the FHA in general: FHAClaims

[http://r20.rs6.net/tn.jsp?llr=zy6u9cdab&et=1108002314545&s=8721&e=0016_oENn

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32FW0z6FKGzQ==].

One reader wrote, "We haven't been able to do much with FHA streamlines

since the 5% change. The .90 and 1.15 change just made it nearly impossible.

People in FHA  loans only put down 3 or 3.5 percent, we know values are

dropping and they wonder why FHA loans have higher default ratios.

Conventionally you have the HARP program but just as they moved the end date

from 6-2011 to 7-2012 they need to move the purchase date for Fannie or

Freddie to everyone can take advantage of the program or at least from

5-2009 to 5-2010. These things seem so easy to figure out. We see the

problem but we aren't taking the necessary steps to solve it. With rates

this low something needs to be done immediately to help people refinance.

Let's not wait until rates begin to go back up. People being able to

refinance and save money will allow for more spending which is what the

economy needs."

All real estate is local. In Manhattan, "The East Village one-bedroom,

one-and-a-half-bathroom condo that he bought for $859,000 was a 'tremendous

value' that he couldn't pass  up, he said." Value? I am sure that any buyers

would qualify for an FHA loan. Actually I don't know that, but once again

the FHA is the target of conjecture and theories about its business plan and

long-term prospects. On the 19th, "Due to our commitment to focus on

application volume that we can acceptably process and close on-time,  Bank

of America is temporarily suspending New Applications on selected Government

Programs, Property types, and Products" for retail sales, centralized sales,

and  fulfillment channels. BofA told its agents, "The following FHA and VA

Programs are being suspended: All "Off-Us" Refinances (Rate and Term,

Cash-out and Streamline) All Cash-out Refinances, loans on the following

property types are being suspended for FHA and VA Purchases and Refinances:

Manufactured Housing Unique Property Types (Log Homes, Earth Homes and Earth

Berm Homes)."



HUD reiterated the current status of, and possible future changes to, its

HECM program.

"FHA is currently in the process of revisiting its regulations to propose

and ultimately adopt changes that are necessary to make the HECM program

[http://r20.rs6.net/tn.jsp?llr=zy6u9cdab&et=1108002314545&s=8721&e=0016_oENn

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JqB_eeq_UuAe95MzwgCYWI6FCKqOjWH_cJ]

even more successful."



For next week's Chicago conference Bill from Provident writes, "I can't wait

to attend the paperless technology meeting when less than 5 investors /

lenders I know will accept electronic signatures. Wasn't it Bill Clinton

that signed into law the acceptance of paperless? Or was it Calvin

Coolidge?"



I mentioned the Chicago MBA conference. John from Wells Fargo reminds us

that the Chicago Marathon is Sunday (sponsored by BofA!), and that many

roads are actually closed. The gall - didn't they know the MBA was coming to

town? RunAway!RunAway!



[http://r20.rs6.net/tn.jsp?llr=zy6u9cdab&et=1108002314545&s=8721&e=0016_oENn

KksZm7G0NQjHC9d2PKq-p3oVJrF4qBsXmsUK-MI0yDmB3r_cijbd5TJYAlNoyJHPpFzeBSuI6I9p

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bG_tUyyEruXQ==]



MERS has something to be pleased about: an Arizona federal judge dismissed

72 lawsuits against it, with the judge relying on a September appellate

court decision and rejecting the argument by plaintiffs in the consolidated

litigation that naming MERS as a beneficiary on deeds of trust means they're

unsecured and the properties can't be foreclosed. He said, "This court does

not find legal support for the proposition  that the MERS system of

securitization is so inherently defective so as to render every MERS deed of

trust completely unenforceable and unassignable," Teilborg wrote in his

order dismissing the claims. Of course Valerie Edwards, co-lead plaintiffs'

counsel, said plaintiffs plan to appeal, because that is what attorneys do.

"Rob, even though the NMLS does not allow a LO to take the same CE course 2

years in a row, that does NOT mean they cannot use the same provider for

their CE education.

 They just have to make sure the provider gets a different course approved

each year. Mortgage Training Today will be doing one course each year, so

they can use us over and over again!" So noted Barbara Werth with Mortgage

Training Today. (If you have questions send her a telegram at




As of 9/30, new or existing MLOs have completed over 462,739 hours of PE

(pre-licensure) in 2011, equating to approximately 23,136 MLOs.

Approximately 321,427 hours of CE has been completed equating to

approximately 40,178 MLOs or about 47% of the estimated 85,000 MLOs who are

expected to complete CE in 2011.

Tuesday I wrote about appraisals, and confusion on some of the rankings, and

received this note: "I'm looking for  someone knowledgeable with the new

appraisal regs -  in particular these new C-4, C-5 and C-6 rankings -- and

how investors are going to interpret them, who might be interested in coming

to New Orleans to speak at my managers meeting next week. Do you happen to

have any thoughts on the subject?"

If that perks your interest, write to Paulina McGrath, the president of

Republic  State Mortgage at psm@rsmc.net [mailto:psm@rsmc.net].



Fannie has new policies for loans that become delinquent after 10/1 "to

streamline and simplify servicing processes, help servicers to contact

delinquent borrowers  more effectively, determine eligibility and offer

foreclosure prevention alternatives to struggling homeowners." Your

servicing group had better know them! ServicingRequirements

[http://r20.rs6.net/tn.jsp?llr=zy6u9cdab&et=1108002314545&s=8721&e=0016_oENn

KksZk7HwemzkHneci42KvPatYiArlo65MdK7bkriamseupg7xHCPhiYX_c_G_KqmFOLUJD0DOCYS

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GcjW76E3GJGfZjHbFepf8LkA==]

And while you're at it, on 10/12 Fannie's "Property Maintenance and

Management:

Property Preservation Matrix and Reference Guide" will become effective.

MowThatLawn!

[http://r20.rs6.net/tn.jsp?llr=zy6u9cdab&et=1108002314545&s=8721&e=0016_oENn

KksZndJxTyatZMu7M7uGRcrqWr52pDB_Nl_rnwuek0LDFIT-ra5Jppckr2lNEh80v53AnbOlqnvM

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3xe9HBGS33_7yL4dOp0Lu0eAmUU1OieUqEwpd4NR47Iok=]

The FDIC is very good about posting the banks examined for CRA compliance

[http://r20.rs6.net/tn.jsp?llr=zy6u9cdab&et=1108002314545&s=8721&e=0016_oENn

KksZmL3OCJPFhPdiuihAAkGunhg50gVUhhMFc45fVMyEH0-up8kJYFqw4aGilniKpxl_x3b_P4r2

RNwixDbKm1gxQyfUbmPPdaA5HUe1M0dLXzQeACChdzXfgwUuvjpSZvqfvrSL020n3Pu_7q6D-Amd

6lpJPXwga0l58=].

Investors such as GMAC, PHH, and Home Savings of America reminded clients

that Monday is a legal public holiday and it may not be counted in the three

and seven day waiting periods or the three day right of rescission, nor will

funds be wired, nor will banks or post offices be open. "HSOA (and GMACB)

offices will be open that day and the lock desk will be open normal hours."



"Effective immediately, Home Savings of America is temporarily suspending

our offering of the 203K program."



GMAC Bank's correspondent clients will see a new rate sheet on 10/11. Anyone

with spreadsheets tied to it had better get to work!



PHH told clients that, "USDA Rural Development issued an announcement

indicating  that funding for the Single Family Housing Guaranteed Loan

Program will not be available for a short period of time at the beginning of

fiscal year 2012, which  began on October 1st, 2011. During the temporary

lapse of funding, Rural Development will issue Conditional Commitments

"subject to the availability of commitment authority"

for purchase and refinance transactions. PHH will continue to close/fund

loans with Conditional Commitments issued "subject to the availability of

commitment authority".

Citi came out with its usual list that no one wants to find themselves on:

ineligible originators. "This list shows brokers, correspondents or other

loan originators whose loan originations (or who have any role in the

origination) are not acceptable to Citi for purchase." The Citi Ineligible

Originator list (along with ineligible

appraisers) is posted on the Citi Correspondent website

[http://r20.rs6.net/tn.jsp?llr=zy6u9cdab&et=1108002314545&s=8721&e=0016_oENn

KksZmXrb5LX_AijToZYFQ4erITkXN4kjUspLFsxGubsyO5YEHkTBNehkOyrFPfUQm7MG05OhfdXQ

4sIhslQb2xBaZSYt-zPqNMy79jTZr11Xa65n6q2vosReqeHWbX-nBmrMycvzmDDmAqeSXnvf6xII

exVexTqEqGV7g=].



Chase is revising the list of approved Appraisal Management Companies (AMCs)

for  Non-Agency loans. The list of Chase-approved AMCs for Non-Agency loans

has been  reduced to two AMCs: LSI and Equifax. "A Chase-approved AMC must

be used to order the appraisal for any Non-Agency loan sold to Chase.

Appraisals for other products may be ordered by the Correspondent directly

or through an AMC of the Correspondent's choice."

How long will our stock and bond markets go through the yo-yo caused by what

happens in Europe? A long time, apparently. "Treasury prices lost ground

yesterday after  reports surfaced that EU was working on a plan to support

imperiled European banks.

This reoccurring story removed the luster from the flight to quality bid and

sent treasury yields higher. Prices are continuing to edge lower this

morning as investors wait for the actual details of the rumored plan." They

have a plan, then they don't have a plan, they have one, and then they

don't... So yesterday treasuries sold off (the 10-yr worsened more than a

point and closed with a yield of 1.90%) while equities gained. MBS prices

were marked lower by about .375.



Today we had weekly Initial Jobless Claims for last week: the previous

week's was revised from 391k to 395k, and last week's rose 6k to 401k. No

big deal. At 8AM PST  the Treasury announces details of next week's auctions

of 3- and 10-year notes and 30-year bonds - estimated unchanged at $66

billion. Stay tuned for tomorrow's unemployment data, but for now the

10-yr's yield is up slightly at 1.94% and MBS  prices are worse by .125.



(Parental discretion advised.)



Grandma and Grandpa were visiting the kids and grandkids overnight.

When Grandpa found a bottle of "enhancement pills"in his son's medicine

cabinet,  he asked about using one of the pills.

The son said, "At your age I don't think you should take one Dad; they're

very strong and very expensive."

"How much?"



"$10 a pill," answered the son.

After they left the next morning, the son found $110 on their bed.  He

called his father's cell phone. "Dad, I told you each pill was $10, not

$110."

"I know. The hundred is from your mother."



Rob



(Check out


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slOn8RTJAeyXToe1fyYXGB1bkz5kIV2PnxRksJdRQrh_X_UfVkvMQVMTh4yu63Ef5FjGAbU4s_OG

_U5GoEAKzEcwSICJ76kF5sOQ==]




[http://r20.rs6.net/tn.jsp?llr=zy6u9cdab&et=1108002314545&s=8721&e=0016_oENn

KksZmXDXbHnpFSFaQSzpeNS8RF8Dh2bhNL7ITvY9_B_CfmIy37M6IUmlMnXYI_EVlM8uY4oYjkPP

Mnjv8Zty5tALTtrjosvA06NYTPALrOYsmhPthXTOeURUCfqtxPq4A3v8QKzHsZuNC0SA==].

For archived commentaries, go to www.robchrisman.com

[http://r20.rs6.net/tn.jsp?llr=zy6u9cdab&et=1108002314545&s=8721&e=0016_oENn

KksZkvsKf4NYyG1DjTIvwTKox6EJm727riMKy3Hhe-mbeMqZvKKFavZtzBThgHvP8z5ihAk5pSiS

JnW1nz_uuNPrG5FggLs2cY70nRZbud7QFtcg==].

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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