Friday, July 26, 2013

Honesty

http://globalhomefinance.com


What is a forint? Besides being a good scrabble or hangman word, it is the

currency of Hungary. I mention this because, in Hungary, borrowers can have

mortgages based on foreign currencies, and the government has embarked on a

plan to have all mortgages based on paying in forints. Stuff I never thought

of: HowAboutYapStoneMoney?

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iXF95Bj8r8EM35nZpunci8MsKILGRth92nFzomv1VievSQ4JamRMo5Y3ovi0ZhmdDVuZwPt1SB5W

Q9kThj9ffbBLEt494-50azVa5_NjZ-8lJ5nCynz8tZiJhRArzLfqa17BPbp4fQIVblMVklSUQmIB

YG6wPpQcxU5729h5-ZhxF3Sr1imggb2fmuOwITE=]

 

I am fortunate enough to do a little speaking, and in fact next week am

heading to New York for a Sterling National Bank event. But I received this

note. "Rob, do you know anyone at the CFPB who can speak at our annual

meeting?" All requests for CFPB speakers can be directed to


 

"Teamwork is essential because it allows you to blame someone else."

Sometimes banks and mortgage banks work together, sometimes not. "Rob,

someone told me that bankers want more regulations. What's up with that?" I

have spoken to a number of bank managers and top brass. Banks have been

regulated from Day 1, whereas it is hard to argue  that mortgage banks

("those cowboys!") had had the same burden. But everyone knows that mortgage

banks, and their LOs, are quickly catching up - maybe, as they say, mortgage

banking is as heavily regulated as banking but it just doesn't know it yet.

But it is little surprise that mortgage banks view the increased regulatory

burden as anything but a cost to be passed on to borrowers, although when

pressed management will admit that many lenders and LOs who should not have

been in the business have left - a good thing. In the meantime, bankers have

pretty much been saying, "Welcome to our world. Our residential lending,

policies, and procedures  have been policed for years, and if you'd don't

like it, we'll be glad to take your market share." That's it in a nutshell -

banks may not exactly want more regulation, but they are comfortable in the

environment, and have compliance and legal staffing to absorb it.

 

Banks, for their part are seen (at least on the commercial side) taking on

more risk by using a familiar funding tactic that works fine as long as

rates remain steady - but if rates increase more, watch out! It is not news

that the average maturity of loans has extended significantly (especially

true in community banks).

Banks are full of cash and have very low loan-to-deposit ratios, and are

trying to find decent commercial loans. The number of loans with maturities

over 5 years for banks under $1 billion in assets has increased from 14% in

2007 to 27% as of

 Q1 2013, according to Pacific Coast Bankers Bank. "That near doubling has

regulators concerned and bankers are beginning to face questions about

contingency plans, stress testing and other factors during recent

exams...Some have begun to utilize FHLB advances once again to match-fund

longer maturity loans" which helps interest rate risk management. But when

loans prepay, the bank no longer has that income generating asset, yet it

cannot unwind the funding without significant cost. And with FHLB advances,

the bank is using wholesale deposits support loan growth - and regulators

take a hard look at that since it is not "core" funding and uses up

contingent liquidity and requires collateral. That adds pressure and takes

away flexibility.

 

Unlike mortgage banks, where warehouse costs tend to rise in a rising-rate

environment, banks tend to "enjoy" the environment as rates move higher. For

most banks, deposit costs lag the overall rise in interest rates, and

profitability soars (just look  at how well bank stocks have done lately),

as retail deposit costs remain far below the cost of institutional deposits.

Some banks, instead of going after wholesale  deposits, are considering

booking a floating rate asset right from the get-go.

 

And let's not forget Basel III's impact on many banks. Changes to regulatory

capital will likely drive larger banks to change the way they invest. To

address the capital impact of price movement in their investment portfolios,

look for larger banks to take actions that include shortening their

duration, moving more securities to HTM, holding more loans versus

securities, holding more capital, or buying more floating rate securities.

Larger banks are already doing this, as are community banks.

 

While I am yapping about banks, Wells Fargo announced that it is eliminating

its  entire remaining joint venture mortgage banking affiliates. Is it a big

deal for Wells? Not really - it only has eight nonbank lenders in this

program which accounted for 3% of the 2nd quarter mortgage production. But

two years ago it had 100 mortgage JVs. And folks who think about these

things say the timing is interesting, with the announcement coming so soon

after the CFPB/Castle Cook news. Remember Wells'

 decision to pull out of wholesale after the Department of Justice

settlement? Wells, and other investors, has been burned in the past on

behalf of their counterparties, and this channel is not viewed as scalable.

 

Winding down the eight joint ventures will take 12-18 months, and it is

believed  that other large aggregators may step in and throw them a life

ring. Wells may actually make a couple traditional correspondents. (The

eight are Bankers Funding Company, Colorado Mortgage Alliance, DE Capital

Mortgage, Home Services Lending,  Military Family Home Loans, Premia

Mortgage, Prosperity Mortgage, and Priva LLC.) But it is truly a sign of the

times, given the current regulatory and market environment, and changes in

state and federal oversight have increased the complexity and difficulty of

operating these joint ventures. It is rumored that HomeServices, at $4

billion a year, will move over to Berkshire Hathaway.

 

I received a few notes saying this reminded readers of the news that broke

in May regarding Paul Taylor Homes in Texas. "A Texas homebuilder will

surrender more than

$100,000 to the Consumer Finance Protection Agency under a consent order

filed on Friday. Paul Taylor, a principal of Paul Taylor Homes Unlimited and

Paul Taylor Corporation was accused of receiving kickbacks for referring

homebuyers to Benchmark Bank and to Willow Bend Mortgage Company for their

mortgages. Under the agreement Taylor is also prohibited from engaging in

future real estate settlement services including mortgage origination." As a

reminder: MND

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iLpLu_7owwsjhm3Coo2fkdWtq8tNoJkgzvNyCsvuzK_Q0IZvphaQ2D_V1KKy7VxHYr1dPjjGhh2l

6kSMn2HT5xTQqWHATiGSNkJpOUuXs-LtXFwdpkzJedbX7yYraEY=].

 

Three down, fifteen to go. Huh? UBS Americas will pay $885 million to settle

ongoing litigation with the Federal Housing Finance Agency (which oversees

Freddie Mac and Fannie Mae) over the bank's sale of toxic residential

mortgage-backed securities  to F&F. The FHFA has alleged that the various

banks violated federal and state securities laws when selling private-label

RMBS to the housing agencies. Under the terms of the settlement, UBS will

pay approximately $415 million to Fannie and $470 to Freddie to resolve

certain claims related to securities sold to the entities between 2004 and

2007. You might remember some of these names, as the settlement  agreement

covers claims between FHA and UBS in the following cases: FHFA v. UBS

Americas, Inc.; FHFA v. Ally Financial Inc.; FHFA v. Countrywide Financial

Corp.; and FHFA v. First Horizon National Corp. Of the 18 suits filed in

2011, FHFA has  now settled three cases and remains committed to

satisfactorily resolving the remaining

suits: UBS

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74XhzGvj-vaV1cX8k6yT9Onl2LUQRtvgUDoDDO2Yp0_zJAMMt6wkp5Earw_zHrQ5MpS7ELRoFT_J

vnkikSiiBMEJGvqn25H3WXnF6u56I50CxH7qkpANpouz6a52uvaobYhcgoxbwo-b3dcMP7th16ck

Y8GMEjgHPnbv8xfAGBWXq0KOg9MOm4EgNZjkS94=].

 

Under the "two steps forward, one step back" category, Lender Processing

Services

(LPD) will be reporting a huge spike in the U.S. loan delinquency rate when

it releases its Mortgage Monitor for June. Mortgage News Daily reports, "the

total delinquency rate for June was 6.68 percent, a 9.91 percent increase,

month over month, in the rate which includes loans 30 or more days past due

but not in foreclosure. This jump follows five straight months of decline.

The company offered no explanation  for the surge beyond referring to it as

"seasonal". There were 3,328,000 mortgage loans in the 30+ delinquent

category at the end of June. Of these loans, 1.3 million are seriously

delinquent, that is 90 or more days past due."

 

Let's take a look at some recent vendor, investor, and agency news - it just

keeps flowing.

 

Money manager Hank Paulson sure likes Radian, given its recent stock

performance.

"When Radian Group Inc. sold shares in 2010 to bolster capital, the buyers

lost more than a third of their investment in just two months. The mortgage

insurer's  offering in February, backed by money managers including John

Paulson, is proving second chances can work. Radian has rallied 73 percent

to $13.87 since selling shares for $8 apiece as well as debt in February.

Rival MGIC Investment Corp. has followed a similar pattern, slumping after a

2010 offering and surging 45 percent since this year's $1.15 billion capital

raise." Here you go: RiskReward

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5JAAYcRReYaOr6VzpU0H8l6UwXulyTf195P6n9fDuQcZTogfbXF6zexysS4A7ZbkfOVNsWhHFqWy

Ju_nADzPJct_BQsRuZ8sycwi8T6VJlizx5Fgor1n05_Q0Zhm5_Jia5d0Ajmz1PARctIH_C6egoDQ

GseHsJ_xSCGBZ2QY1LDieu8t5Ig4].

 

Florida Capital Bank Mortgage (FCBM) will now offer financing to purchase

transactions in the State of Alabama with an unexpired Right of Redemption

after a Foreclosure.

Documentation to protect the lender from loss should the right of redemption

be exercised will be required. The required documentation will depend upon

the difference between the foreclosure sales price and the loan amount of

the new lien. The Guidelines are posted on the FCBM website www.flcbmtg.com

[http://r20.rs6.net/tn.jsp?e=001TWE4PRNArIxzxRlHVGvYkNWRNaD4KR2bszxrg-DyQSr2

mJu84IM_INz_4EZTMk8HpTsE8s5g02AvDF_ztxo90H9VCHI-PFIaKY7ZkDVJ3NSIFSno5rxJvw==

].

 

FNMA has published what appears to be a "just checking in" memo on the

CFPB's QM  and Ability to Repay regulation, which is scheduled to go into

effect on January 10th of next year. Until the CFPB issues a final rule on

Refi Plus, DU Refi Plus, and loans sold under written variances to the

Selling Guide, Fannie will continue purchasing these loans but will be

monitoring market dynamics in the meantime to  assess the possible need for

any underwriting, eligibility, and/or pricing changes.

The post-purchase file review, repurchase requirements, and/or updates to

the reps and warrants framework are also being assessed as they pertain to

the new regulations.

 

For those having difficulty resolving Fatal Edit 72 (the Appraisal Document

File  Identifier field) when delivering loans to Fannie, a new job aid is

available via the Fannie website.

 

FNMA has made it a requirement that servicers accept modification assistance

from a Housing Finance Agency for mortgage loans in connection with any FNMA

modification, whether or not principal forbearance is required. In cases

where the borrower completes a Trial Period Plan but the servicer does not

receive the HFA funds before the due date of the first modified payment, the

servicer must re-evaluate the borrower's  eligibility for a modification,

and loans for which borrowers are no longer eligible must be sent to Fannie

for a final decision. If the borrower does qualify for a modification per

the servicer's assessment, the servicer is not permitted to require the

borrower to complete a new Trial Period Plan, even if the modified monthly

payment is higher than it would be in a Trial Period Plan. This policy goes

into effect on October 1st.

 

Cornerstone reminds its correspondent lenders that it will allow a maximum

total  of 28 days' worth of one-week extensions. After this, the loan will

be subject to re-locking at the worse of current market or original pricing

minus the extension fees. Jumbo loans are subject to a limit of two

extensions that may not exceed 30 day per investor guidelines; anything that

needs to be extended past this point will be re-locked at worst case

scenario.

 

Risk management firm Secure Settlements Incorporated has begun testing a new

closing table quality control tool that captures closing table loan date,

re-enforces quality control measures, and offers resources for educating

settlement agents about best practices and what to look for in terms of

fraud schemes and money laundering. The mobile app, which is slated to be

launched within SSI's vetted settlement network on September 1st, is

compatible with both Droid and Apple.

 

Well, rates continue to chop around these levels - maybe consumers will

become accustomed to them, and come back in. Yesterday, in economic news,

Weekly Initial Jobless Claims rose by 7K in the latest week to 343K, above

the 340K expected.  Durable Orders had an upside surprise surging by 4.2% in

June, well above the 1.8% expected. And the Treasury auctioned off $29

billion of 7-year notes.  The increase in jobless  claims was attributed to

annual auto-plant shutdowns. Durable Goods, always volatile, was the main

culprit in the sell-off - perhaps an increase in demand will help boost

manufacturing and the economy in the second half of the year.

 

By the time the dust settled Thursday, 10-yr T-notes reached the highest

level in more than a week, and 30-yr T-bonds approached the highest level in

almost two years.

Prior to that, however, agency MBS prices had improved. As far as volume was

concerned, mortgage banker supply was near the 30-day moving average, per

Tradeweb. So if lenders are selling about $1.5 billion a day, and the Fed is

buying about $3 billion a day, the supply/demand picture is still pretty

good for mortgages. There is little news of consequence today. The current

yield on the 10-yr is 2.57%, basically unchanged from Thursday afternoon, so

don't look for a lot of change on rate sheets this morning.

 

Retired person's job interview:

 

Interviewer: "What would you consider to be your greatest weakness?"

 

Applicant: "Honesty."

 

Interviewer: "Honesty? I don't think honesty is a weakness."

 

Applicant: "I don't give a ---- what you think."

 

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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The current blog is, "A Little Technical Knowledge About REITs." 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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For archived commentaries or to subscribe, go to www.robchrisman.com

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