Wednesday, February 19, 2014

Economics & MBS pricing; Dallas Fed study of Bank Capital & Leverage



 

"A statistician is someone who tells you, when you've got your head in the fridge and your feet in the oven, that you're - on average - very comfortable." Statisticians are licking their chops over the new Producer Price Index information that will be released today. "The Labor Department's producer price index had previously tracked only the wholesale prices of goods. Now, beginning with Wednesday's release of January data, the index will also cover services and construction. By tracking what manufacturers and farmers charged for their goods, the producer price index has traditionally provided an early read of inflation trends. It captured how much of the change in oil, grains and other raw material costs was being passed on by producers." This has nothing to do with loan level price adjustments for loans, but figured I'd pass it along.

 

NAMB issued a "Government Affairs Update" for the 2014 Legislative and Regulatory Conference to be held in Washington DC from March 2-4. The organization has offered to let readers & members weigh in on the top 3 questions you would ask the CFPB. For information on the conference write to Richard Bettencourt at governmentaffairs@namb.org.

 

Historically, the Wells Fargo Economics group does exceptional work, and their current paper titled The Labor Market and Credit Risk is no exception. In their first report on this topic, the group focused on the development of the Labor Market Index, which they believe is a more comprehensive measure of the labor market than the unemployment rate. In their second report, they focused on the link between the unemployment rate and the broader economy as measured by real GDP. In this third report, released just prior to the New Year, they ask and evaluate a simple question: How reliable is the unemployment rate as a predictor of credit quality in the modern economy? More specifically, they are interested in identifying a possible statistical relationship between the Labor Market Index and credit market indicators including the delinquency rate and charge-offs over the past 20 years. The cliff-notes version: their conclusion shows that the unemployment rate should not be used solely to predict delinquency rates.

 

The Dallas Federal Reserve has released an interesting economic letter entitled, "Weakly Capitalized Banks Slowed Lending Recovery After Recession." This article finds that large, highly leveraged banks and thrifts followed a softer lending growth path than their better-capitalized counterparts in 2009-10 during the sluggish recovery from, what has now being coined,  the "Great Recession." As we know, commercial banks, credit unions and savings and loans sustained substantial losses during this period. Real estate was especially sluggish, culminating with residential loan delinquencies peaking at 11.3% in first quarter 2010 and com­mercial real estate delinquencies at 8.8%, according to the Dallas Fed research. J.B. Cooke and Christoffer Koch write, "The resulting loan losses ate into bank capital, the first line of defense for large depositors and debt holders, boosting the institutions' leverage. A simultaneous decline in wholesale funding-via com­mercial paper or large time-deposits, for example-reduced the supply of loans...this slow­down occurred even though Fed monetary policy was highly accommodative in a concerted effort to stimulate economic growth." Good economic research can be classified as counter-intuitive, and this is the case with Dallas' recent release. The ultimate conclusion, and argument made by Cooke and Koch is that a reluctance to lend, particularly by those larger institutions with very low ratios of capital to assets, worsened the fiscal crisis; if these institutions had behaved as the other banks did, the cumu­lative amount of loan activity might have been 5-6% higher and might have provided greater support to Fed recovery efforts.

 

A couple weeks ago the National Association of Insurance Commissioners (the NAIC) released its updated breakpoints for RMBS securities based on November 2013 submissions. Why is this important? Because their demand of product helps determine mortgage interest rates. Overall, breakpoints increased across the board largely due to improvements in collateral assumptions reflecting an improved outlook for the housing market. According to a Bloomberg article published earlier this month, "As of this point, STACR and CAS (Structured Agency Credit Risk & Connecticut Avenue Securities) deals have not been included in the year-end results." However, according to NAIC meeting notes, they are under potential consideration to be treated as RMBS and are to be assigned NAIC designations in the future. As a result of these improved assumptions, NAIC breakpoints have improved across the board, especially for the credit-dented sectors. Breakpoints increased by approximately 6-7% for sub-prime, POA and Alt-A ARM bonds compared with 1-3% for prime bonds. In 2013-year end results, around 15% of bonds have been modeled as having zero-loss compared with 11% in the 2012-year end results.

 

On January 14th the Federal Reserve Board, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, and the Securities and Exchange Commission approved a modification to the Volcker rule that would allow banks to keep interests in certain funds backed by trust-preferred securities. The change was aimed at easing small bank's concerns that they needed to dump certain investments they had previously thought would be allowed under the rule, losing money in the process. A bank trade group sued regulators over the dispute, and lawmakers from both parties have backed the banks. Trust-preferred securities, or TruPS, have hybrid characteristics of debt and equity and can get favorable tax treatment. Regulators said banks could keep certain collateralized debt obligations backed by TruPS if they obtained them before the Volcker rule was finalized on Dec. 10: Bloomberg.

 

The Federal Financial Institutions Examination Council (the FFIEC) was established in 1979. By charter, their principle focus is "to prescribe uniform principles, standards, and report forms and to promote uniformity in the supervision of financial institutions." I would bet business is booming at the FFIEC. The Council has six voting members: the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Office of the Comptroller of the Currency, the National Credit Union Administration, the Consumer Financial Protection Bureau, and the State Liaison Committee. Last month, the Council released final guidance on the applicability of consumer protection and compliance laws, regulations, and policies to activities conducted via social media by banks, savings associations, and credit unions, as well as nonbank entities supervised by the Consumer Financial Protection Bureau. The new guidance is effective immediately; its release does not impose any new requirements on financial institutions, but is intended to help financial institutions understand potential consumer compliance and legal risks. The guidance provides considerations that financial institutions may find useful in conducting risk assessments and crafting and evaluating policies and procedures regarding social media. The full release can be found at FFIEC: www.FFIEC.gov.

 

Tasty treats today include the Mortgage Bankers Association report on mortgage applications, the Housing Starts and Building Permits duo for January, along with the Producer Price Index (expected lower). But not so fast! The Bureau of Labor Statistics (BLS) will be rolling out a new version of the Producer Price Index (PPI). The new system for reporting price changes at the producer level aims to "expand coverage and improve upon the current methodology", and give analysts something to talk about like "significant changes, merits, and drawbacks of the new system."

 


 

 

Tuesday, February 18, 2014

MBA Compensation Survey; possible HMDA changes and HARP expansion update



 

The MBA continues to gather information, and came out with its latest compensation benchmarking study. "MBA's benchmarking studies offer mortgage companies better business intelligence when making important personnel and operational changes to adapt to this regulatory climate. For ten years, MBA has recommended the annual Residential Mortgage Banking Compensation Survey Program to its members (and every lender) as they develop and implement their individual compensation strategies. This year's program includes the 2014 Residential Compensation Survey that profiles more than two hundred positions across all mortgage-related lines of business and functional areas. Among the elements covered: base salary, cash bonus, total cash, commissions, overtime, total compensation and long-term/deferred awards. Reports include scoping factors such as geographic region, number of employees, revenue size and total loan volume. In addition, productivity data is collected and included in the report at the individual level (i.e. loan officer loan production); three specialized compensation benchmark products that are focused on production, servicing and corporate/executive functions; a 1½ day MBA Human Resources Roundtable in September. Open to participants in the survey, this interactive workshop offers a unique opportunity for attendees to network with peers, while analyzing the latest in compensation benchmarking data and human resource trends. Results from the 2014 Residential Compensation Survey will be presented. Registration and participation in the program is required in order to receive the results and MBA members receive a significant discount off the regular survey pricing. The survey questionnaires will be sent in March. Publication of the survey is anticipated for August 2014.  Please complete the registration form today to secure your firm's participation in this program, or if you have general questions, please contact Marina Walsh, MBA Research, at MWalsh@mba.org.

 

The MBA is definitely following the HMDA developments. But what do credit unions think of the CFPB's quest for more HMDA information?

 

The MBA sent out an update saying, "The CFPB began the process of revising the Home Mortgage Disclosure Act (HMDA) rules to require lenders to collect and report several new data elements. Some of these new data elements are specifically required under Dodd-Frank. However, the Bureau is also considering requiring some additional data elements. The CFPB is also considering changes to the collection rules to streamline reporting and improve data entry. Finally, it is also considering revising the reporting thresholds so all banks and non-banks report if they make 25 or more mortgage loans in a year. A summary of the data elements sought by the CFPB is here. Notably, Dodd-Frank adds the following HMDA data elements (unless the CFPB decides otherwise): total points and fees, and rate spreads for all loans (not just HPMLs); risky loan features including teaser rates, prepayment penalties, and non-amortizing features; the length of the loan; expanded lender information, including a unique identifier for the loan officer and the loan; property value and improved property location information; borrower age and credit score.

 

The CFPB is also considering requiring: mandatory reporting of reasons for denial; debt-to-income (DTI) ratio; Qualified Mortgage status of loan; combined loan-to-value (CLTV) ratio; automatic underwriting systems results; additional points and fees information (including interest rate - HMDA requires APR currently, total origination charges, Bona Fide and Total discount points, risk-adjusted, pre-discounted interest rate); whether loan has affordable housing deed restrictions; and manufactured housing data.

 

As a first step in revising the rules, the CFPB has convened a small business review panel required under the Small Business Regulatory Enforcement Fairness Act (SBREFA) to provide input on the changes under consideration, focusing particularly on the burden these requirements would create. Over the next few weeks, the CFPB will conduct several conference calls with the SBREFA panel and an in-person meeting in Washington DC in early to mid-March. Following the conclusion of the panel's work, the CFPB is expected to issue a proposed rule. At least four members of the panel are employees of MBA member companies and MBA is acting as a resource to industry panelists. MBA believes that the new data collection requirements present several important concerns that must be resolved to avoid undue operational burdens and litigation risks-especially in light of HUD's recent disparate impact rule. MBA also wants to ensure that consumer privacy is not compromised under any new HMDA regime. MBA will raise these and other issues in the rulemaking process. We are at the beginning of what should be a lengthy process. Any new HMDA rules are unlikely to require new data until 2016 at the earliest. We will provide updates as this important process moves forward."

 

Has anyone head about the government expanding HARP? If they do, will we see another refi boom?" I hate to be the bearer of bad news, but a story in Bloomberg last week filled us in. "HUD's Donovan Confirms HARP Won't Be Expanded, FBR Says." "Now HUD has joined the Treasury on doing nothing with regard to HARP, which makes it a bit more difficult for Watt to garner support for material changes." "HUD Secretary Shaun Donovan made it clear yesterday at a Politico event that his department. Will not push for HARP expansion, confirms that no broadening of program should be expected, FBR analyst Ed Mills writes in a research note. Donovan believes improving access to credit for mortgage borrowers remains HUD's most important policy challenge. Sees Wells Fargo's pursuit of 600-640 FICO FHA borrowers as positive sign for credit availability. Donovan is cautiously optimistic about FHA's finances; following last year's infusion of taxpayer money into FHA, many in Washington concerned about its balance sheet."

 

Monday, February 17, 2014

Mortgage servicing market continues to chug along; Lender & Investor Updates



Underwriters will soon be entering that netherworld where they want 2013 tax returns, but borrowers just don't have them yet. With that in mind, here's a little trivia from our compatriots at the IRS: 47.8% of the individual income tax returns filed in the USA for tax year 2011 reported less than $30,000 of adjusted gross income. The mortgage and financial services sector has more than its fair share of personnel who made that in a month last year, and the year before. Maybe not this year...although generally the gap between the haves and the have not's seems to be widening.
 
The market for servicing is roiling. The average borrower doesn't know that the rights to service their mortgage may be sold and bought (creating a letter they receive in the mail saying they will start sending their payments somewhere else). Despite the apparent speed bump that the market has seen on the demand side from non-depository servicing buyers basically waiting for regulators to tell them if they have enough capital to keep going and keep their stockholders happy, the supply continues.
 
Today is a federal holiday, so news might be light. So let's use the opportunity to catch up with some relatively recent lender, investor, vendor, and agency updates - they just don't stop. And as always, it is best to read the actual bulletin for full details
Software provider Mortech, a division of Zillow, has enhanced the compliance capabilities of the Marksman pricing engine to integrate the APR/POR rate check spread, applicable DTI limits, and requirements for the lender fees and points calculation.  Users are issued with a full compliance worksheet that provides an overview of the loan scenario at both the application stage and when the loan is locked and discloses which test have been performed and the test results. Home Ownership and Equity Protection Act rules, investor eligibility, and a workflow for anti-steering that allows the lender to print an anti-steering disclosure form.
 Per Regulation Z, Wells Fargo is requiring that all individuals who have an ownership interest in the property be provided with a fully executed Notice of Right to Cancel.  This applies to all loans, including those where a non-vested individual is deemed to have an ownership due to state laws based on community property, homestead, dower/curtesy, etc.  Wells will also accept a Spousal Waiver, Warranty Deed, or transactional Quit Claim that shows that the non-vested individual no longer has an interest in the property in lieu of the Notice of Right to Cancel.
 Wells has updated guidance to state that electronically signed documents from TPOs or mobile apps will be ineligible for purchase and that electronic signatures may not be applied to multiple electronic records simultaneously.  Loan packages with electronically signed documents must include evidence of Borrower Consent Language showing that the borrower agreed to receive and sign any application documents as such.
To align with Fannie's updated guidance, Wells is now requiring condo and PUD projects to have gap dwelling insurance policies if the amount of the HOA blanket coverage is between 80% and 100% of the replacement cost.  Loans on properties in projects with insurance that covers less than 80% of the replacement cost will not be eligible for purchase.
Effective for all commitments, re-locks, or re-negotiations dated February 17th or after, Wells is requiring that all loan files include the updated Loan Submission Summary.  As a reminder, the revised LSS features a new Disclosed Index Rate that must be completed for Conventional Conforming ARMs to meet the Agencies' ULDD requirements.
 US Bank is now offering 5/1 ARM loans with a 2/2/5 cap structure and a new FHLMC Super Conforming 7/1 LIBOR ARM program.  The latter is available for primary residences, second homes, and investment properties and offers a cash-out option.  The new program is subject to the same 5/2/5 cap structure of the existing FHLMC Conforming 7/1 LIBOR ARM.
FAMC has rolled out a new Conventional 10/1 ARM product, available for purchases, rate/term refis, and cash-out refis.  The program uses the same cap structure (5/2/5) and qualifying rate guidelines as the Conventional 7/1.
Penny Mac is now offering a Jumbo program to all correspondent lenders with a TNW of $2.5m and above.  Loan amounts of up to $2 million are available for 1-unit purchase transactions with an LTV at or below 70% and a FICO of at least 720.
The markets are closed today, so pricing folks either aren't pricing, or are looking at the Asian & European markets (who for some unknown reason don't celebrate President's Day along with us) and adding in some cushion just to throw something on rate sheets. We're coming off a Friday that had a weaker-than-expected Industrial Production number, but (go figure) stocks rallied and bond prices sank. Investors appear to be discounting recent data due to bad weather.
 Inflation has not been an issue for many, many years, but still analysts talk about it - especially when there isn't much else to talk about. And this week we'll have the monthly inflation reports: the Producer Price Index (PPI) and its sibling the Consumer Price Index (CPI). They come out Wednesday and Thursday, respectively. The minutes from the January 29 Federal Open Market Committee Meeting will be released on Wednesday, as will Housing Starts. Its cousin Existing Home Sales will be released on Friday. Throw in the Philly Fed and Empire State numbers and that about does it.
 


Friday, February 14, 2014

Wells' volume up to 65% purchase & "edging" into subprime!





 A new study has found that women with large backsides live longer than men who mention it." I couldn't resist that one, given today being February 14th - and I make up for it with the joke at the end. I don't know what Melissa Burch looks like, but she represents the pain in the backside that our business has in improving public relations. Just when you think title folks are all as "pure as the driven snow", along comes this story: "Melissa Burch, a real estate closing agent at a Fort Lauderdale title company, pocketed more than $1 million from her employer's escrow accounts, police said." Andrew Liput, president of Secure Settlements, observed, "This unfortunate incident demonstrates the need to marry industry best practices with independent risk evaluation, ongoing monitoring and rapid real time reporting. Motive and opportunity can often lead to fraud, but independent oversight is a strong deterrent to bad actors. (It is rumored that Secure Settlements is in discussions with large settlement firms and title agencies exploring the best ways to combine best practice guidelines with data intelligence and risk metrics to reduce these types of criminal acts.)

 

As Wells Fargo goes, so goes the residential lending biz? Wells Fargo has cut its retail staff by 50%, volume is down 60% versus a year ago, but its purchase volume percentage is above 65% and it is pursuing non-QM IO loans for its own portfolio. How the heck did all that happen?  Here you go: Transition.

 

And now a story that Wells is "edging" back into subprime mortgages due to declining volumes and revenues. Didn't we all hear this story ten years ago? But seriously, this is truly indicative of current events. I see depository institutions using the advantages that they have (low cost of funds, deposit bases to match assets to and create portfolio products, being accustomed to a heavily regulated environment, and existing staff of trained mortgage employees) to press their advantage over other companies - and probably not through the wholesale or correspondent channels - at least initially.

 

Wells is now accepting the Doc Magic Loan Detail Report and the fee details forms from Byte Software and PPDocs in place of the Wells Fargo Fee Details Form.  The Compliance Ease full Compliance Analyzer report will also be accepted in lieu if all individual fees paid outside of closing by the borrower are clearly identified on the Final HUD-1.

 

Mountain West Financial has updated its income guidelines for both Conventional and Government loans to require borrowers with less than two consecutive years of employment history to provide documentation showing a prior immediate history of school attendance or enrollment in a training program relevant to the current position. With regard to mortgage insurance premiums as they pertain to the QM Points and Fees rules, MWF has clarified that lenders should exclude borrower-paid Monthly Premiums, monthly portions of borrower-paid Split Premiums, and lender-paid Upfront or Monthly Premiums in the calculation.  Premiums paid by the borrower at closing, such as borrower-paid Single Upfront (both refundable and non-refundable) and the upfront portion of the borrower-paid Split Upfront Premiums, are to be included in the calculation.

 

 

 Rate are hanging tough, and improved yesterday on a weaker-than-expected Retail Sales number for January, which is expected to result in downward revisions to Q1 growth outlook, and on an unexpected increase in Initial Claims. The 10-year note improved .5 in price, closing at 2.74%, and agency MBS prices improved .250-.375 on lower-than-recent-average volumes

 

In a dark and hazy room, peering into a crystal ball, the fortune teller delivered grave news:

"There's no easy way to tell you this, so I'll just be blunt. Prepare yourself to be a widow. Your husband will die a violent and horrible death this year."

Visibly shaken, Laura stared at the fortune tellers lined face, and then at the single flickering candle, and then down at her hands.

She took a few deep breaths to compose herself and to stop her mind racing.

She simply had to know...

She met the fortune teller's gaze, steadied her voice and asked..."Will I be acquitted?"

 

Happy Valentine’s Day!

 


 

 

Thursday, February 13, 2014

The market for servicing is spooked, which could hit mortgage pricing



A report from the CFPB on January 30th says that mortgage servicing issues remain a top concern for the agency. The CFPB's supervisory work completed between July and October 2013 uncovered the same sort of mortgage servicing problems that occurred in 2009 and 2010, as banks were overwhelmed with record numbers of home foreclosures. The report claims servicers violated the Dodd-Frank Wall Street Reform and Consumer Protection Act's ban on unfair, abusive or deceptive acts and practices in a handful of areas, such as payment processing, the transfer of servicing rights and providing borrower information to consumer credit reporting bureaus. Examiners found that two servicers engaged in unfair practices by failing to honor existing permanent or trial loan modifications after a servicing transfer, which resulted in borrowers being charged the wrong amount or being told to pay the wrong amount. Agency examiners also found that two servicers were requiring borrowers to waive any existing claims in order to get a forbearance or loan modification agreement. The examiners found these broad waiver clauses to be unfair as they were done without regard to individual circumstances. The end result of the agencies efforts and due diligence have been fines and penalties levied against the institutions it oversees; according to the CFPB consumers have received $2.6 million as result. Mortgage Servicing Problems?



 Is two years a long time nowadays? Maybe I'm not the most qualified to judge, considering I can't even remember what I received for Christmas 40 days ago. Thanks to Barbara Mishkin of Ballard Spahr for including, and commenting, on Washington Post article regarding the history of the CFPB. The story reads more like an episode of "Days of Our Lives" than it does an hour watching C-SPAN. I guess that will happen when pools of talented labor are drawn from the private and public sector, and meet in a sort of micro-meets-macro government Thunderdome type scenario. The article is good, taking the reader from concept to implementation; through confirmation of the current Director; to employee turnover (yes, there has been substantial turnover in two years). For an agency not-yet up to flank speed, the challenges and expectations have never been greater.

Updates on some Lender & Investor from recent weeks

 Fannie Mae has updated Desktop Underwriter to align with the VA 2014 county loan limit changes, which went into effect for all casefiles submitted or re-submitted after January 18th. As of April 1st, Fannie will require servicers to send a notification to borrowers with mortgage loan modifications with a step interest rate adjustment that includes the amount and effective date of the increase; the amount and due date of the new monthly payment; an explanation of how the interest rate cap was set and how it will be fixed once it reaches the interest rate cap; a payment schedule table; an explanation that the monthly payment includes an escrow for property taxes, hazard insurance, and other escrowed expenses which, if changed, will change the monthly payment; an explanation of how the new monthly payment was determined, servicer contact information and instructions to contact the servicer with any questions; the Homeowner's HOPE Hotline number and instructions to ask for Making Home Affordable help; an explanation that the borrower can seek assistance with household budgeting from HUD-approved housing counseling agencies; and information on additional educational resources at Fannie's Know Your Options website.

 As part of Ginnie Mae's modernization efforts, issuers are now required to access the Ginnie Mae Enterprise Portal in order to request Commitment Authority, for which they must authorize their selected bank to accept ACH debits from BNY Mellon for the commitment fees.  Lenders are also able to submit master agreements, requests for pool numbers, and requests for commitment authority directly through the GMEP and must upload their master agreements by March 31st.

Per the January 10th rules, Wells Fargo is requiring that all submitted loan package include evidence of how the DTI was determined.  In recent weeks, DTI Review has recorded an influx of loan files where the documentation does not support the calculated debt, the credit inquiry letter is not complete, and debt and/or income documentation is missing, resulting in suspense conditions.  Lenders are encouraged to use the Income and Debt worksheet; however, alternative forms will be accepted provided they reflect all monthly income types for each borrower, how the monthly income was determined, the total qualifying income, the primary residence PTI, the front and back end DTI ratios, the total monthly debt from the final AUS/credit report/1003, any additional debts not listed on the credit report, an explanation for debts not included in the DTI, and a list of all documentation used to support how the underwriter derived the total income and assets.



Wednesday, February 12, 2014

Clarification of 3% Fee and State Compliance News of Strict Requirements



 

There is a note: "We are now being told by several legal sources that affiliate title companies fees for broker don't need to be counted in the 3% fee rule for QM.  Are you hearing anything about this? We were told only lenders, correspondents and table funders needed to count the affiliate title fees into the 3% fee rule.  When management heard this from inside and outside counsel we concluded that it doesn't make any sense that brokers would be excluded from that rule.  We are also hearing from one of our brokers, when we informed then they needed to restructure a loan because it didn't met the QM standard, they said other lenders are not counting those fees toward the 3% rule."

 

The CFPB discounts that notion, and requests lenders to take a look at the actual language of the definition of points and fees for closed-end mortgages, which is found in 1026.32(b)(1); specifically, 32(b)(1)(iii)(C) is what's relevant here (and even more specifically, see the words within that paragraph that should be regarded): (b) Definitions. For purposes of this subpart, the following definitions apply: (1) In connection with a closed-end credit transaction, points and fees means the following fees or charges that are known at or before consummation...(iii) All items listed in §1026.4(c)(7) (other than amounts held for future payment of taxes), unless: (A) The charge is reasonable; (B) The creditor receives no direct or indirect compensation in connection with the charge; and (C) The charge is not paid to an affiliate of the creditor;". Yes, it appears that means that fees paid to affiliates of brokers aren't included in the Points and Fees test unless they otherwise would.

 

Keeping on with regulations, Illinois has adopted several changes to the registration fee requirements for loan originators. The changes included the addition of an exempt entity registration fee, constituting a $657 increase from $2,043 to $2,700 annually. This fee is broken down into an investigation fee and initial application fee. Nicole Legere of Bankers Advisory writes, "The applicant must pay a $1,500 dollar non-refundable investigation fee which is an increase from the prior fee of $1,135 dollars. The applicant must also pay an initial license fee of $1,200 dollars which is an increase from the prior fee of $908 dollars.  These fees can be paid separately or as a singular combined fee based on the discretion of the Director of the Division of Banking. Applicants for license renewal will face the same overall increase in fees as the annual licensing fee is being raised to $2,700 dollars." These changes have already been implemented.

 

The Washington State Department of Financial Institutions writes, "It has come to our attention that clarification is needed on the following rule WAC 208-620-301. Your managers, including branch managers, must license individually as mortgage loan originators if they conduct the following activities: (1) Take residential mortgage loan applications, negotiate the terms or conditions of residential mortgage loans, or hold themselves out as being able to conduct these activities; (2) Supervise your loan processor or underwriting employees; or (3) Supervise your licensed mortgage loan originators."

 

As further clarification Washington writes, "(1) Any manager or any person who takes a residential mortgage loan application in Washington, negotiates the terms or conditions of a residential mortgage loan on Washington property, or holds themselves out as being able to conduct those activities, must have a Washington MLO license. Washington licensed MLOs must work from a licensed location. (2) Any manager who directly supervises loan processor or underwriting employees must hold an MLO license. The MLO license can be from any state. Washington licensed MLOs must work from a licensed location. (3) Any manager who directly supervises Washington licensed MLOs must themselves hold a Washington MLO license.”

 

Interest rate markets started early this morning with a little more selling after yesterday’s Yellen testimony that affirmed the Fed is still on track to continue its tapering at the March 18th and 19th FOMC meeting. Prior to her testimony to the House Financial Services Committee yesterday there was some concern among analysts she would come out with a different agenda than Bernanke; we are puzzled that there would be any concern since she was a direct influence and in complete agreement with Bernanke’s policy of accommodation and the current tapering. Goes to show that even the obvious can be cloudy. Yellen was widely known as a dove on accommodation, why would anyone think otherwise?

 

 

Monday, February 10, 2014

What's on the agenda for today?


MBS OVERVIEW
The much anticipated Non-Farm Payroll report arrived and it really disappointed. As a result, MBS shot up but then something interesting happened. They sold off and by the time your first live pricing is posted by your investors or secondary marketing department, many of you will only see a very small improvement in pricing. Watch today's video and read below for more.

ECONOMIC DATA
Non-Farm Payrolls: Where a big disappointment. The market was expecting 185K new jobs but only got 113K. We have been stating that any reading below 160K would be positive for MBS. But just as important as this reading was the prior reading which if you recall was a big-time miss at only 74K. The market expected significant revisions upward but it was only revised up by a mere 1K to 75K. MBS shot up initially as a result.
Unemployment Rate: This dropped from 6.7% down to 6.6% but as we have discussed, bond traders largely ignore this reading. The only reason it has significance to traders is the 6.50% trigger that the Fed had originally pegged to their Fed Fund rate but they have recently stated that they would keep their rates low even after the Unemployment Rate breaks below 6.50%.