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That doesn't necessarily mean every LO should be rooting for civil unrest
and the
collapse of Greece, however. But just look at some of the things that have
happened
out there: Chinese manufacturing contracted for the 4th straight month. Iran
refused
to let inspectors into certain nuclear sites, Euro manufacturing came in
lower
than expected, Fitch downgraded Greece, the Bank of England minutes came out
more
dovish than expected, oil prices are above $108 per barrel...the list goes
on and
on. Meanwhile, our rates and currency remain relatively stable, and our
markets
relatively liquid: a safe haven - and this is helping our mortgage rates.
There is plenty of blame to go around for the mess we're in: borrowers,
brokers,
lenders, investors, appraisers, rating agencies, investment banks, and so
on. The
rating agencies have begun to come under more scrutiny, since their role
ties together
many of these parties. Credit rating agencies have been widely criticized in
recent
years for the poor performance of their ratings on mortgage-backed
securities (MBS)
and other structured-finance bonds. In response to the concerns of investors
and
other market participants, the 2010 Dodd-Frank Act incorporates a range of
reforms
likely to significantly reshape the rating industry. Too lengthy to mention
in this
commentary, more details can be found 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==]
where the current blog discusses the role of rating agencies in the current
environment.
Can't the mortgage industry go through a week without some piece of big news
breaking?
Bank of America "is cutting off Fannie Mae from loans starting this month,
except
for modifications and some refinancings (Making Home Affordable Program),
because
of Fannie's stance on repurchases, Bank of America said yesterday in a
filing. The
firms are in talks to end the disagreement, the bank said." Bank of America
is in
plenty of lawsuits, and spending $1.5 billion a quarter on legal fees,
including
some against MI companies, many of whom contract with Fannie Mae after the
fact
to resolve loan issues long after what some would assume is a "reasonable"
amount
of time. In November, BofA said it refused to cooperate with what it deemed
a new
Fannie Mae policy that required loan repurchases if an insurer drops
coverage. Should
we care? Maybe, maybe not - after all, since Fannie & Freddie are both
controlled
by the FHFA and the U.S. government, loans are still destined for the same
basic
place. Here is the complete story
[http://r20.rs6.net/tn.jsp?t=h9d55fjab.0.ymxm5fjab.zy6u9cdab.8721&ts=S0732&p
=http%3A%2F%2Fwww.bloomberg.com%2Fnews%2F2012-02-23%2Fbofa-halts-routing-new
-mortgages-to-fannie-mae.html].
Anyone can sign up for the CFPB Junior Rangers Program. (I made that up -
the program
doesn't actually exist.) But if you'd like to have input, and something
nifty for
that resume, the CFPB is looking for experts for its Consumer Advisory
Board. "If
you know anyone with innovative ideas and a keen perspective on how consumer
finance
markets affect American consumers, we want to hear from you! Learn how you
can submit
a nomination for our Consumer Advisory Board." Check it out at DoIGetABadge?
[http://r20.rs6.net/tn.jsp?t=h9d55fjab.0.zmxm5fjab.zy6u9cdab.8721&ts=S0732&p
=http%3A%2F%2Fwww.consumerfinance.gov%2Fwere-taking-nominations-for-our-cons
umer-advisory-board%2F]
Wednesday I noted some NMLS statistics from another publication. It turns
out that
they were somewhat misleading, some would say incorrect, but fortunately an
official
from the
Conference of State Bank Supervisors wrote to me all the way from Washington
DC
to set the record straight - thank you. Here are the most up-to-date,
accurate numbers
for licensing: LicensingData
[http://r20.rs6.net/tn.jsp?t=h9d55fjab.0.9mxm5fjab.zy6u9cdab.8721&ts=S0732&p
=http%3A%2F%2Fmortgage.nationwidelicensingsystem.org%2Fabout%2Fdocuments%2Fq
uarter-3-2011-licensing-data.pdf].
And looking into the numbers, Joel Brenner, Compliance and QC Manager with
imortgage,
wrote, "Rob, regarding the NMLS statistics showing growth in the branch and
License
LO areas, we have to remember that with banks going out of business, or LO's
who
previously worked for exempt organizations now joining the ranks of
mortgage banking
many LO's who previously didn't need a license will have to obtain one. It's
possible
for the licensure statistics to rise even with continuing consolidation in
the jobs
arena for LO's."
I love stories like, "In response to a Financial Times report indicating
that the
five biggest U.S. mortgage servicers can credit actions under the Home
Affordable
Modification Program toward their obligations to the $25 billion national
foreclosure
settlement, HUD insists that the deal will not be subsidized by taxpayers.
Agency
officials clarify, "For HAMP modifications that do include principal
reduction,
servicers only receive credit for the portion of the principal reduction
that they
themselves pay for, not for the portion covered by incentives in the
program." There's
an old saying, "The government can't give what it doesn't take from someone
else
first," and whether it is the taxpayers, or from banks' depositors, the
money has
to come from somewhere.
While we're on HUD, many believe that FHA is a "ticking time bomb." HUD's
certainly
working on a different timeline than Fannie & Freddie: the GSEs' problems
are mainly
from the weak credits of 2005-2008, but FHA/VA wasn't insuring any loans in
the
bubble years. Their volumes have been surging since 2009. And even though
the 2009-2012
FHA/VA vintages are "better" loans, they're still FHA/VA loans, and many
believe
that future defaults will be significant. So in volume terms, Ginnies will
be
facing peak default and buyouts over the next 2-4 years. What this means for
investors
and lenders is more buyouts, more modifications, and ongoing pressure on the
FHA
insurance fund, which makes HUD much more likely to raise MIPs than to drop
them.
FHA Commissioner Galante recently said that the FHA would announce
additional premium
changes to new mortgage business and streamline refi loans in the coming
days.
Although changes to FHA premiums are widely expected, she was quoted as
saying that
"we will be making changes to the streamline refinance program structure of
premiums
soon to achieve greater use of the program". The language suggests that she
may
be referring to the possibility of grandfathering in FHA premiums for
streamline
refi loans or capping their fee to the existing 110 basis points even if
fee for
non-streamline refi's were to increase further. She also mentioned that the
changes
would affect loans written prior to May 2009, "when the insurance premium
structure
was very different from what it is today." The May 2009 date creates some
confusion
as FHA premiums were first increased in October 2010. Co-incidentally, May
2009
is the current cut-off date for the HARP program which makes it even more
confusing.
Regardless, MI companies are very pleased with the news.
Although there is still a fair amount of uncertainty on this issue, if the
comments
are accurately quoted, the likelihood of grandfathering premiums for FHA
loans in
the case of streamline refinancings is definitely much higher. If this were
to happen,
2009-2010 Ginnie 4.5 prepayments could increase dramatically. And what
investor
wants to own mortgages that are expected to pay off soon?
IMMAAG has issued a "Call to Action" after meeting with members of Congress
and
with D.C.-based mortgage industry associations "who share similar even if
not totally
congruent concerns about the direction recent legislative and regulatory
actions
have taken and the absence of justification for such initiatives." The
action focuses
on the LO compensation guidelines - yes, they're still an issue, especially
with
the CFPB issuing its "Notice of Streamlining Project, Request for
Information",
a five page request in the Federal Register for the public to share its
concerns
and identify its highest priorities for regulatory streamlining by March 5,
2012.
"Document your specific (but unidentified) examples of consumer harm
associated
with the April 2011 Loan Originator Compensation Rule and what makes it
harmful
and a direct result of changes required by the rule. Send that as quickly as
possible
aggregated
with all those received and will be sent directly to Mr. Carroll in response
to
his request." Statements can also be sent to that address on appraiser
independence
(required by the Dodd Frank Act), the Red Flags Rule and any other
regulation.
Housing and jobs, jobs and housing. The FHFA's index, focused on property
values
for Freddie and Fannie radar screen, showed that house prices fell modestly
in
the fourth quarter of 2011: -.1%. Over the past year, seasonally adjusted
prices
fell 2.4% from the fourth quarter of 2010 to the fourth quarter of 2011.
No one can really complain about mortgage rates, and Thursday saw several
intra-day
price changes. Originator volume was lower than average, easily soaked up by
the
Fed's daily purchases (what happens when that goes away?) and other
investors buying
production. MBS pricing improved by about .250 in price, and our 10-yr
closed around
1.98%. And there is not much news moving our markets, at least in this
country -
the only thing we have is Consumer Sentiment for February and New Home
Sales. Rates
are pretty much unchanged from Thursday's close, with the 10-yr at 1.98% and
MBS
prices unmoved.
(Parental guidance suggested.)
Sometimes it is good to look at the "flip side" of things - in this case 3
minutes
[http://r20.rs6.net/tn.jsp?t=h9d55fjab.0.8mxm5fjab.zy6u9cdab.8721&ts=S0732&p
=http%3A%2F%2Fbiggeekdad.com%2F2012%2F02%2Fthe-flip-side-of-dating%2F]
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 discusses the role of rating agencies in the current
environment.
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
[http://r20.rs6.net/tn.jsp?t=h9d55fjab.0.epg7qedab.zy6u9cdab.8721&ts=S0732&p
=http%3A%2F%2Fwww.mortgagenewsdaily.com%2Fchannels%2Fpipelinepress%2Fdefault
.aspx]
[http://r20.rs6.net/tn.jsp?t=h9d55fjab.0.v7uif6dab.zy6u9cdab.8721&ts=S0732&p
=http%3A%2F%2Fwww.thebasispoint.com%2Fcategory%2Fdaily-basis].
For archived commentaries, go to www.robchrisman.com
[http://r20.rs6.net/tn.jsp?t=h9d55fjab.0.fpg7qedab.zy6u9cdab.8721&ts=S0732&p
=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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