Out in Northern California the weather is generally good, and Triserv Appraisal Management Solutions is searching for a Regional Sales Executive for that area. Triserv is a national appraisal management firm.  “With a service-first culture, national panel of appraisers and integrated technology, Triserv is able to offer a seamless appraisal process. In turn, we remain focused on building customer confidence, improving operational efficiencies and driving performance.  Our ultimate goal is to create sustainability for the appraisal management industry. And if investor repurchases are an issue,  Triserv has a team of experienced work out specialist with a proven track record of assisting our clients cure 60% of prior appraisal related investor repurchase requests.” If you’re interested, or know someone who is, contact Brad Harvey, the Director of Sales for the West at bharvey@triservllc.com.

As mentioned Friday in the commentary, Provident Funding told its clients that “condominiums are now unacceptable properties except for high rise condominiums located in Chicago, Honolulu, San Francisco and Seattle.” I received several inquiries into why the company did this. "Rob, here's my theory as to why Provident made that change. It drives its costs down, and Provident historically hasn’t offered products that are higher cost to originate. Condos cost more to originate because of the additional work that the lender has to do to get the project approved, or the additional risk that the lender takes in supplying reps and warrants for condos to the agencies. If Provident’s goal is to not originate higher cost product, this makes all the sense in the world, and look for others to follow. And high-rise condo complexes mostly likely already have agency approval – just a theory.”

And this note: “I wonder if Provident is tightening their underwriting guidelines to improve their execution in the secondary market.  Pools with Provident as the servicer are a major red flag (for prepayment risk: extremely low rates + heavy TPO) in the MBS market and one of the reasons why Gold/FN swaps have been so negative since Provident is primarily a Freddie servicer.”

And lastly on Provident’s condo change: “This type of property type does not fit Provident’s ultimate quality model in terms of both marketability and occupancy fraud. In addition, the staff has other priorities than to deal with the additional underwriting burden (the Condo Cert and the Master Insurance Policy and the Annual Budget and the HOA lawsuits and the surprise assessments to cover maintenance and capital improvements that were not reserved for by incompetent, part-time, volunteer HOA Boards.”

Turning to other investors, here are some happenings in the banks from the past couple of weeks:

In an on-again-off-again process that took 9 months, the Fed officially approved Capital One Financial’s $9 billion acquisition of online bank ING Direct. The transaction moves Capital One to the 5^th largest bank based on deposit size.

Citi updated its Ineligible Originator List, a database of brokers, correspondents, and other loan originators whose loans originations are not eligible for purchase.  The full list can be viewed on the Citi Correspondent website, along with the Appraiser/Monitor Ineligible List, which is updated regularly.

The Consumer Financial Protection Bureau has issued new examination procedures for payday lenders.  Be warned: they’re very thorough.  The procedures are divided into five “modules”: marketing; application and origination; payment processing and sustained use; collections, account in default, and consumer reporting; and third party relationships.  The modules are so designed to ensure compliance with six federal statues and regulation set out under Dodd-Frank’s UDAAP provision.

As most know, the FHA and HUD have decreed that mortgagees participating in the Lender Insurance programs are now required to reimburse HUD for self-endorsed loans that are ineligible for FHA insurance. (So why would any company self-endorse??)

A couple weeks ago the FHA announced new regulation that aims to protect the Mutual Mortgage Insurance Fund by strengthening the requirements of certain lenders to reimburse HUD for insurance claims on mortgages that don’t meet HUD guidelines.  As of February 24th, all lenders with authority are subject to stricter performance standards that will determine their approval status as well.  The full release can be accessed at http://portal.hud.gov/hudportal/HUD?src/press/press_releases_media_advisories/2012/HUDNo.12-010.

Fannie Mae has rolled out several Selling Guide Updates. On January 31, for example, Fannie Mae issued Selling Guide Announcement SEL-2012-01, which provides updates and changes regarding (i) Construction-to-Permanent Financing; (ii) effective quality control plans, and (iii) other miscellaneous Guide topics. The changes to the Construction-to-Permanent Financing provisions aim to more closely align the policies related to such financing with standard requirements for other refinance transactions. The updates to the requirements for the lender to have an effective quality control plan do not establish any new policies, but seek to clarify requirements for lenders' post-closing quality control process. For a copy of the Fannie Mae Announcement, please see https://www.efanniemae.com/sf/guides/ssg/annltrs/pdf/2012/sel1201.pdf.

On 1/31 Freddie Mac issued Bulletin 2012-3 to formally extend the Uniform Loan Delivery Dataset (ULDD) implementation schedule. ULDD mandatory compliance is now required for all loans submitted to Freddie Mac on or after July 23, 2012 (previously March 19, 2012). To provide a transition period, Freddie Mac will update its system for the ULDD data points on April 23, 2012 (previously January 23, 2012). The Bulletin also alerts sellers as to the Single-Family Seller/Servicer Guide updates requiring new ULDD data points for all mortgages with application received dates on or after August 1, 2012 that are delivered on or after November 26, 2012. Lastly, the Bulletin notifies sellers that Appendix A of the Implementation Guide for Loan Delivery Data has been updated to reflect these changes. For a copy of the Freddie Mac Bulletin, please see http://www.freddiemac.com/sell/guide/bulletins/pdf/bll1203.pdf.

Going on, Fannie Mae has expanded guidelines on retirement assets such that liquid retirement assets that can be withdrawn without penalty can now be converted to income, and borrowers can use 70% of the retirement account to qualify. Fannie now has blanket delegation of authority on behalf of PMI Mortgage Insurance servicers, which means that the latter no longer requires separate mortgage insurer approval when processing foreclosures sales or deed-in-lieu of foreclosures.

Freddie Mac has issued new requirements for non-assumable Guaranteed Rural Housing mortgages as well as amendments to GRH-related terminology.  Written approval to sell these mortgages is mandatory, and if you’re looking for a chapter on “Mortgages for Newly Constructed Homes” and “Newly Built Home Mortgages,” don’t bother—Chapter K33 has been renamed “Construction Conversion and Renovation Mortgages.” Sellers are also reminded of the disclosures required of Freddie under Dodd-Frank: all securitizers (including GSE’s) must disclose information on ABS and loan purchasing requests, the latter of which includes the originator’s identity.

Freddie Mac HARP Overview sessions for housing counselors will be available on a number of dates throughout February.  These sessions are aimed at nonprofit housing counseling organizations and provide an overview of the changes to HARP and borrower, mortgage and property eligibility.  Registration info can be found at http://www.freddiemac.com/corporate/housingpros/harp_overview.html.

Contingent upon borrowers’ ability to meet the minimum contribution, Fifth Third is allowing gift funds to be used for reserves on primary residences. Fifth Third have also issued reminders that as of November 30, 2011, they no longer accept loans that contain Trust Agreements; full documentation is required for all Super Conforming loans.

Guild Mortgage spread the word to clients that it will now close DU Refi plus loans covered by mortgage insurance.

In accordance with the CFPB’s ruling that the USDA annual fee is no longer considered mortgage insurance for RESPA and TILA disclosure purposes, Home Savings has tweaked the way forms are filled out.  Loans disclosing USDA Guarantee Fees as mortgage insurance will be processed as a changed circumstance. A few weeks ago HSOA told clients that 15-, 30-, and 45-day locks are now available on all programs.  Although they had previously indicated that 60-day locks were limited to the HS1000 program, a correction has been issued stating that 60-day locks are not available at all.

Back in November 2011, US Bank announced the HASP/HARP enhancements but was then forced to delay.  The new Delivery Fee Cap reductions are now available for new locks taken on these programs’ loans so that, if the amortization is less than 20 years, the cap is reduced to zero, and for amortization is greater than 20 years, the cap is reduced to .75%.  Investors are reminded that these reductions apply solely to owner-occupied and second homes with LTVs of more than 80%.

Wells Fargo Wholesale is revising its policies on pipeline loans in accordance with Dodd-Frank (daily trivia: Dodd-Frank is apparently allowed to “exert preemption” over select state laws).  The changes, which come into effect on March 1st, will impact pipeline loans in California, Iowa, Kansas, Massachusetts, New Jersey, Tennessee, and Wyoming in a variety of areas, so it’s worth checking out the full matrix. As of March 1st, loans for attached condos and PUDs will be subject to changes in Hazard Insurance guidelines requiring more comprehensive coverage.  Note that this won’t affect detached units, and should the development’s master policy provide walls-in coverage, the borrower will not need to obtain their own policy. And starting today, Wells will no longer originate originating Tablefund loans in Kansas due to restrictions outlined in the Kansas Uniform Consumer Credit code.  The same goes for originating Traditional loans with a LTV/CLTV/TLTV of more than 100%.

Due to a high volume of incoming membership applications, Flagstar has announced that MERS will be extending the deadline for originators of loans with MERS as the original mortgagee from February 27 to March 31. Other recent changes at Flagstar include some tweaks to the Loantrac system, guidelines for New York CEMA loans, and conventional underwriting guidelines, the last of which is to comply with the modifications to Freddie Mac transactions.

Affiliated Mortgage Company has decreed that all conventional loans closing more than 30 days prior (reduced from 45 days) to their purchase by AMC must have an Appraisal Update to ensure that the property’s value hasn’t declined from the time of the original report.  All conventional loans delivered for purchase on or after February 21 will be affected. A wag of the finger: due to a large number of loans AMC has purchased that had incorrect and insufficient documentation of the borrower’s receipt of appraisal reports, all loans delivered on or after February 21 will require a full Appraisal Independence Requirements Borrower’s Acknowledgement Form.  The form must be executed at least 3 business days before closing.

Instead of a joke today, how about a little presidential salary trivia? Presidents began the 1900’s with annual salaries of $50,000. This was raised to $75,000 for Taft, Wilson, Harding, Coolidge, Hoover (Herbert did not accept a salary – he gave the money to charity), Roosevelt, and Truman. (During Truman’s administration presidents began receiving an allotment of $50,000 per year for expenses.) The salary was raised to $100,000 for Eisenhower, Kennedy (he did not take a salary), and Johnson. Inflation really began to kick in as it was raised to $200,000 for Nixon, Ford, Carter, Reagan, Bush, and Clinton, and then another raise in 2001 to $400,000 for George W. Bush and Obama.