Thursday, February 23, 2012

February 23: Volker Rule's impact on hedging rate locks; potential HARP 2.0 borrower pool defined; AMC's calling their tax attorneys?

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Money is money, right? If Congress can place a "mortgage tax" in the form of

higher g-fees, and use the money to help cover a payroll tax waiver

extension, can the states use the mortgage servicer settlement money to pay

for chalk in classrooms

[http://r20.rs6.net/tn.jsp?et=1109366297430&s=8721&e=0015DroUx3evLTLS7w8VJoA

dAm1okzIdB3DKza-3wLS2i4oKytXm6aDkq1ca41qLHY9hrzLFcklJDdwyoIEmnllJimrxIjU-R6r

UQVNgoXxR9BV4YKJ3xSJmFy_x3e4LLHuE-ljQFVgUszJdsApE8CP_A==]?



How much is $1 trillion?  One thousand million is a billion, and one

thousand billion is a trillion.  According to Business Week, outstanding

student debt in the United States is approaching $1 trillion-that is $3,333

per head for our population of about 300,000,000.  Is this an example of

living beyond one's means?  The Federal Reserve noted in a White Paper last

month that the current mortgage lending standards are holding back younger

first-time homebuyers.  Student debt has, for the first  time in the US,

surpassed credit card debt, with recent university graduates carrying an

average load of over $25,000.  Even if recent graduates are able to secure a

high-paying job (no small feat in a time when unemployment for 29-34s is at

9%),  a number like that makes getting a loan difficult.  A young medical

professional, for example, may make upwards of $125,000 a year, but there's

a good chance he or she will also be carrying over $100,000 of student debt.

The article points to the trend that the student debt issue is yet another

reason that record-low interest rates aren't invigorating the housing

market.  First-time buyers make up a good proportion of demand, but they've

been disproportionately affected by tightening credit and mortgage

conditions.  The percentage of 29-34's who obtained first-time mortgages

between 2009-11 was 9%, just about half of what it was a decade previously.



My parrot broke his leg today so I made him a little splint out of a couple

of wooden matches, and his little face lit up when he tried to walk.

Unfortunately, I forgot to remove the sandpaper from the bottom of his cage.

Speaking of unintended consequences...As if mortgage bankers and

depositories don't have enough to worry about, the Volker Rule should not

escape notice. Will rate locks be a thing of the past with the Volker Rule?

In the broadest sense it prohibits banks using MBS to hedge production. In

an interview on CNBC last week, John Stumpf noted that the way the rules are

coming down, they are "very broad in their prohibitions and very narrow in

their permissions.

Let me give you one example. When we make someone a mortgage, we give them a

free rate lock for 60 or 90 days, and if rates go up, even if only by .250%,

that's thousands of dollars over the life of a loan. If (The Volker Rule)

gets implemented the wrong way we might not be able to do that - we hedge

that, we swap that, and we'd have  to have such a gigantic group of

consultants, accountants, attorneys making sure that doesn't (go against the

rules). Here is more

[http://r20.rs6.net/tn.jsp?et=1109366297430&s=8721&e=0015DroUx3evLR301JHr_k8

ILsS3mG_pud0Ch4zWzVQb2UnxDYUu7rT1WBKCAGN2OmFip90pr9seVDMZmvZaFKVw2FlZ1dQRG0p

JS9CAbOTa5IVygsTf0Qebf-T61DuvVGWZQZLuYRxe-J03WR6cxaDR80A0dYnnJYsHVBNJkb2fMYe

WpZNJd4P_MJucKXexGN-K10RdnVTI_qxlLGae0XH4mXLvGx0DuV6-eCw38vxkqNnSDTgYk-LuQ==

].

And how about contemplating the consequences of having AMC contracts

declared null and void? Last week, the commentary noted that NAIHP issued a

press release regarding appraisal management companies. NAIHP discovered

many AMC's were operating without authority in numerous states and failed to

pay state income tax. Most states won't issue a taxpayer I.D. number unless

a business is registered. And as we all know, all businesses are required to

register with the appropriate authority in any state (usually the Secretary

of State), prior to conducting business - often displayed  in the lobby. I

was contacted by an industry veteran who advised me that, "Any business that

fails to register in any state may find contracts they signed in the normal

course of business to be null and void. In the specific case of an AMC, any

monies collected from consumers while operating without authority, would in

all likelihood need to be refunded." This could be a huge quagmire for

AMC's, many of which are lender-owned.



What is the potential HARP 2.0 borrower pool? "First, as to the size of the

market:

From our HARP 2 workshops, although there are 6.7 million HARP eligible

loans based on the May 31, 2009 cutoff date and Fannie/Freddie requirement,

when payment history and LTV requirements are overlaid, the number of

eligible loans drops to around

2.3 million. And, as the interest rate distribution indicates, a meaningful

proportion of these loans are already at low or fairly low interest rates.

So, assuming that

2 million loans are refinanced under HARP 2, and average $150,000, HARP 2

represents about $300 billion in incremental production over 2012-2013,

about a 15% increase in overall projected volume. Equally important, is that

the profit margins available to lenders for HARP 2 loans could be 2-3 times

what the normally realize, because of lower cost streamline processing and,

in the case of existing services, a captive base of borrowers. Thus, HARP 2

represents a big opportunity for the big aggregators but may not trickle

down to the smaller originators. So the comment that 'smaller originators

will be ideally positioned to pick up market share' is questionable unless

the large aggregators agree to purchase HARP 2 loans from smaller

correspondents.

 While we think they will, they may limit such purchases to only their

largest correspondents and possibly only those correspondents with a direct

to consumer channel." Thanks to STRATMOR, Tranzact Information Services, and

Financial Literacy Systems (run by Garth Graham) for this input.



Originators know that appraisals, equity, and underwriting/documentation are

keeping a lid on lending. But could mortgage rates go even lower? I doubt

it, but then there's this story in the Wall Street Journal...Mortgage rates

should be even lower - the differential between the average MBS rate and the

mortgage rates quoted by banks  is nearly 1%, much higher than normal.  If

the normal relationship between the two rates held, 30yr mortgage yields

would be about 3.4% versus the 3.9% now being quoted! Check out the story

[http://r20.rs6.net/tn.jsp?et=1109366297430&s=8721&e=0015DroUx3evLQqkfjPDARA

pjWhXKFjZXEZPjR6kSCWDykj0WMDXr2ykpWCHgjtobdAxTlrnBBXfCZc_rKXtUMNRl8D_8MpiUmf

KWw5_hnV6XXlEwIHODsH58rFFZVPQJDuJwQa0Wf8zPegeOkc4D-SfRUzR7RovV2FDtmsrgnA-jsT

YhcBP-O4mZrehPEyXzk4].



Jobs and housing, housing and jobs - both are key indicators for the health

of an economy. Yesterday we learned that Existing Home Sales rose 4.3%. The

increase in sales has reduced the number of homes on the market to its

lowest level since April 2006. The median price fell 4.6 per cent in the

month to $154,700, down 2 per cent from the same month last year. Existing

Home Sales numbers have shown an impressive run recently, increasing in four

out of five months. On a year-ago basis, existing home sales are up 3.6% -

but before the celebration starts, remember that we're seeing a lot of

contract failures, and a good portion of transactions continue to be

distressed with all-cash sales making up 31% of total sales. Many investors

are buying discounted properties in select markets and renting them out,

which certainly helps unsold inventory numbers: total housing inventory fell

9.2 percent to 2.38  million, which represents a 6.2-month supply.



According to the Mortgage News Daily, housing affordability as measured by

the National Association of Realtors Housing Affordability Index (HAI) rose

during the last quarter of 2011 as housing prices continued to decline and

interest rates stayed at record lows. The national HAI reached a record high

of 184.5 where the base of 100 is defined as the point at which a

median-income household has enough income to qualify for  a median-priced

existing home with 20% down and 25% of the income devoted to mortgage

payments. This index shows that prices are down about 4% from a year ago -

attributed in part to foreclosures and short sales. Better affordability is

certainly a good thing.



Yesterday rates improved during the day, resulting in many intra-day price

changes

- and we haven't seen too much of that lately. We had a good old-fashioned

"flight to quality bid" that was related to Greece. The 10-yr closed at

about 2.00% and MBS prices tagged along for the ride by improving about .250

in price.



For today's excitement we have Initial Jobless Claims and the FHFA House

Price Index for December at 10AM EST, along with a $29 billion 7-yr T-note

auction - the last Treasury auction for a few weeks. Applications for

jobless benefits were unchanged in the week ended Feb. 18 at 351,000, the

fewest since March 2008, per the Labor  Department. The number of people on

unemployment benefit rolls dropped to the lowest level since August 2008 -

is everyone giving up the search? Rates have moved slightly higher on the

news, as one would expect.



An Englishman, a Scotsman, an Irishman, a Welshman, a Latvian, a Turk, a

German,  an Indian, several Americans (including a southerner, a New

Englander, and a Californian, an Argentinean, a Dane, an Australian, a

Slovakian, an Egyptian, a Japanese, a Moroccan, a Frenchman, a New

Zealander, a Spaniard, a Russian, a Guatemalan, a Colombian, a Pakistani, a

Malaysian, a Croatian, a Uzbek, a Cypriot, a Pole, a Lithuanian, a Chinese,

a Sri Lankan, a Lebanese, a Cayman Islander, a Ugandan, a Vietnamese,  a

Korean, a Uruguayan, a Czech, an Icelander, a  Mexican, a Finn, a Honduran,

a  Panamanian, an Andorran, an Israeli, a Venezuelan, a Fijian, a Peruvian,

an Estonian, a Brazilian, a Portuguese, a Liechtensteiner, a Mongolian, a

Hungarian, a Canadian, a Moldovan, a Haitian, a Norfolk Islander, a

Macedonian, a Bolivian, a Cook Islander, a Tajikistani, a Samoan, an

Armenian, a Aruban, an Albanian, a Greenlander, a Micronesian, a Virgin

Islander, a Georgian, a Bahaman, a Belarusian, a Cuban, a Tongan, a

Cambodian, a Qatari, an  Azerbaijani, a Romanian, a Chilean, a Kyrgyzstani,

a Jamaican, a Filipino, a Ukrainian, a Dutchman, a Ecuadorian, a Costa

Rican, a Swede, a Bulgarian, a Serb, a Swiss, a Greek, a Belgian, a

Singaporean, an Italian, a Norwegian and

47 Africans walk into a fine restaurant....

"I'm sorry," says the maƮtre d', scrutinizing the group one by one and

barring their entrance, "you can't come in here without a Thai."



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

site  located at www.stratmorgroup.com

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jQauayNXQjni-Hc9Sseu-hhZcR1ujeZyAEpw==]

. The current blog discusses residential lending and mortgage programs

around the world, part 2. 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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.aspx]


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=http%3A%2F%2Fwww.thebasispoint.com%2Fcategory%2Fdaily-basis].

For archived commentaries, go to www.robchrisman.com

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=http%3A%2F%2Fwww.robchrisman.com%2F].

Copyright 2012 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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