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Nov. 11, 2011: Reader input on LO comp, MI changes, servicing for the agencies, HARP 2.0, and FHA Streamlines
Rob Chrisman
Here
we are at 11/11/11: Veterans Day. Veterans Day originated as
“Armistice Day” on Nov. 11, 1919, the first anniversary of the
end of World War I. Congress passed a resolution in 1926 for an
annual observance, and Nov. 11 became a national holiday
beginning in 1938. President Dwight D. Eisenhower signed
legislation in 1954 to change the name to Veterans Day as a way
to honor those who served in all American wars. Per the Census Bureau
there are roughly 22 million veterans in the United States,
1.6 million of which are female. 2.4 million are black, 1.2
million are Hispanic. Age-wise, 9 million veterans are 65 years
old or older, while 1.7 million are younger than 35. War-wise,
7.6 million are Vietnam-era, 4.8 served during the Gulf War
(1990 to the present), 2.1 million from WW II (including my
father), 2.6 million from the Korean War, and 5.5 million from
peacetime only. And for more "fun with numbers," three states have 1
million or more vets: California, Florida, and Texas.
Michigan has seen its share of economic ups and downs, and the
resulting swings in mortgage lending. Michigan Governor Rick
Snyder signed legislation providing harsher penalties to those
who knowingly engage in mortgage fraud. The new Michigan laws make
mortgage fraud a specific felony, which will enable courts
to sentence offenders to both jail time and fines depending on
the value of the fraud. Michigan sentencing guidelines were also
revised to provide for new penalties, including penalties for
notaries that knowingly participate in mortgage fraud. Don’t do
the time if you can’t do the time.
Originators
tend
to focus on new deals, and those in process, rather than
cancelling out loans that went elsewhere. And especially with so
many deals in the works, and pipelines swollen, Secondary Marketing
departments are trying to keep "stale" loans out of their
hedged pipelines, and brokers certainly don't want their
quality/pull-through rankings to be incorrectly dinged. I
even saw one wholesale rep send this to brokers: "If you have
any loans in pipeline that will not be moving forward due to a
low appraised value, please e-mail me the name and loan number.
I need to make sure these are denied correctly, to assure they
don’t count against your Tier Score."
Goldman
Sachs
has plenty of smart people working there, but it may not be
enough to smooth over $15.8 billion in mortgage lawsuits (up
from $485 million three months earlier). But Reuters reported
that Goldman management slightly increased the estimate of what
it may lose on the litigation to $2.6 billion from $2 billion.
“The bigger dollar figures come as investors in mortgage-backed
bond deals have raced to take legal action or enter settlement
negotiations before statutes of limitations expire, and as
investors continue to worry about banks' exposure to big
lawsuits. Goldman also added three European financial firms to a
list of parties that have threatened to sue it, a more fulsome
disclosure than some of its peers: HSH Nordbank, Norges Bank
Investment Management and IKB Deutsche Industriebank AG. For the
whole story: http://www.reuters.com/article/2011/11/09/goldman-lawsuit-idUSN1E7A80DB20111109.
How
‘bout we dip into the mail bag for some recent reader input?
Yesterday
the
commentary mentioned Fannie & Freddie taking a tough stance
on servicer issues, and I received, "We are a very small Fannie
Mae servicer and we have already had two cases of 'compensatory
fees' for not foreclosing fast enough and missing the proscribed
timelines in Fannie Mae’s servicing requirements. In the one case that we
have paid so far, our fee was several thousand dollars!
The other case is pending our appeal (wish us luck). So, it’s
not just the big guys who are getting hit. I can’t imagine what
their 'compensatory fees' must be! Community banks are simply
getting killed by the government onslaught."
Mortgage
insurance:
can't live with it, can't live without it? One MI industry vet
wrote, "I felt compelled to comment on: 'Apparently the higher
MI prices and tighter underwriting standards of the current
environment are enticing.' Actually the MI prices today are
lower than when I started decades ago and are lower than at any
point in those years. Regarding the tighter underwriting
standards - it depends on one's point of reference. Tighter than
the bubble era, yes. But tighter than any point from 1957
leading up to the bubble era, no." Both very good points.
And
more on MI:
“As much fun as it would be to get into a “never ending he
said/she said debate”, your industry vet has selective memory.
With FICO-driven MI pricing there are some current MI price
improvements for high FICO borrowers. These were not available
decades ago. I know I was head of pricing for GEMIC decades ago.
What’s also missing from this vet’s comments are the current
high FICO floors that were a lot lower before the bust and
nonexistent ‘decades’ ago, as in before FICO was even an
accepted standard. As far as underwriting standards are
concerned, today the MI’s are (rightfully) underwriting with
1980s guidelines (because they were the right guidelines). Now,
however, the MI’s are also using 21st century AUS systems fed by
state-of-the-art real time credit & income information and
supported by fraud detection and property valuation systems that
were only dreamed of as little as a decade ago. As they say if
you say you remember the old days you probably weren’t there!
“You had it right, at today’s MI rates and at today’s MI
guidelines the insurance the MI’s are writing should be solid
gold! The problem is
simply: 1) the privately insured market has shrunk
exponentially - maybe 20% of its peak, 2) their old books are
killing them, 3) they can’t raise additional capital like they
did in the 80s to our run the problem because their long-term
viability is totally dependent upon the GSE’s existence -
which is anything but certain.”
And
on LO comp:
"I've been in the mortgage business for 25 years, and it
perplexes me every time I hear a broker talk about their
compensation in terms of they ‘had to do so much more work on a
file due to , credit scores, gifts, multiple buyers or
whatever!’ Do they really think that mortgage bankers or bankers
don't do the same amount of work? We all know this is not brain
surgery to complete 1003's and collect complete documentation.
So why do they pretend it is and the brokers job is so much more
deserving of higher compensation? It is clear to me, after
recruiting for many years that the broker's work ethic is to
fund a couple of loans each month and make the highest
compensation, therefore charging the client higher fees, whereas
a mortgage banker/bank consultants thrives on volume, controlled
compensation, and doing the right thing for the client and the
realtor. If anyone is duped on these false premises it is the
uninformed realtors who refer their clients to brokers who have
‘conned’ them into believing that they are the only ones who can
‘shop for the best price’ and do all the work on the file for
their client."
More on LO comp & the payment of bonuses: "How can so many of our
direct competitors seemingly ignore the clear intent
Dodd/Frank by paying production bonuses through so-called
point banks or overage accounts? Loan Originators seem to
be willing to take significant risk and take flight to those
opportunities, irrespective of the fact that they may be subject
to individual accountability by the regulators, not to mention
the brutal and potential door-shutting penalties that could be
imposed upon their organization. What am I missing???"
And
this comment about the FHA
Streamline program. “If they really want people to be able
to refinance, they should keep the 5% rule in place for
streamlines but if someone purchased or last refinanced at .50%
on their monthly mortgage insurance then they should be able to
do a streamline at that .50%. And so on with the .90% or 1.15%.
We want to help the people but we don’t want it to hurt our
pocketbooks so what do we do.”
Darryl R. from Illinois writes, on HARP 2.0, "Do we know
if there is even any thought of the date being moved that Fannie
and Freddie purchased the loan? Not sure why they believe
prolonging the program would be better than moving the date.
And if you can think of prolonging the program why wouldn’t you
think of moving the date as well. Aren’t we talking about
giving as many people as possible the opportunity to refinance?
Just doesn’t make any sense. If not who can someone try to write
to get this point recognized."
It is the VETERAN, not the preacher, who has given us freedom of
religion.
It is the VETERAN, not the reporter, who has given us freedom of
the press.
It is the VETERAN, not the poet, who has given us freedom of
speech.
It is the VETERAN, not the campus organizer, who has given us
freedom to assemble.
It is the VETERAN, not the lawyer, who has given us the right to
a fair trial.
It is the VETERAN, not the politician, who has given us the
right to vote.
It is the VETERAN who salutes the Flag.
It is the VETERAN who serves under the Flag.
Bless
them all.
If
you're interested, visit my twice-a-month blog at the STRATMOR
Group web site located at
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