Apr. 10, 2012: Mortgage jobs; the CFPB to impact servicing! The Volcker Rule & hedging; Ally business shift; lender updates
Rob Chrisman
Here
is an interesting question to ask your boss: "If a project is
running behind schedule, should the boss add personnel to it in
hopes of speeding it up?" The knee-jerk answer is often "yes"
but when you think about it, it turns out the answer is no: adding personnel to a
project often increases the delay. "The most enduring is
demonstrating Brooks' Law: Adding manpower to a late
software project makes it later. Complex programming
projects, and many roles in mortgage origination planning,
cannot be perfectly partitioned into discrete tasks that can be
worked on without communication between the workers and without
establishing a set of complex interrelationships between tasks
and the workers performing them. Therefore, assigning more
people to a project running behind schedule will make it even
later. This is because the time required for the new personnel
to learn about the project and the increased communication
overhead will consume an ever increasing quantity of the
calendar time available” - I think we've all seen this happen.
Here is the theory: http://en.wikipedia.org/wiki/The_Mythical_Man-Month.
WCS
Lending is expanding its retail and wholesale channels and
searching for experienced mortgage professionals to join the
firm,
including LO's, DE and LAPP underwriters (nationwide), and a
government underwriting supervisor and post-closing manager for
its state of the art corporate facility in Boca Raton, Florida.
(The LO's would join any one of WCS's seven branch locations in
Florida, New York, Michigan, Ohio, Delaware, or Hawaii.)
Established over 10 years ago, WCS Lending is a mid-sized
nationwide mortgage banker that has won Inc5000's for America's
Fastest Growing Private Companies from 2009-2011. For more
information on the firm visit http://www.wcslending.com
and to apply resumes should be sent to jobs@wcslending.com.
WCS Lending is an Equal Opportunity and Affirmative Action
Employer, M/F/D/V.
Mission Hills Mortgage
Bankers, a well-known 42-year retail mortgage originator
(headquartered in Orange County California) continues to grow
and is seeking
underwriters and loan processors for its Orange County
California headquarters. MHMB business plans call for
aggressive expansion throughout the western U.S. Underwriting
positions are responsible for the regional underwriting of loans
from several production offices. Experience requirements
include FHA DE and VA SAR certifications and a minimum of five
years’ experience. Loan processing opportunities are available
in the company’s consumer direct office in Orange County and its
Klamath Falls branch location. Interested parties should forward
resume with salary history to hr@mhmb.com.
Practically every loan originated in the United States has a
rate lock, e.g., the lender has guaranteed a certain rate and
price to a borrower for some amount of time. And this rate lock
is hedged, either by the investor or by the lender, usually by
using MBS's. Could the
Volcker Rule, contained in Dodd-Frank, bring an end to banks
and lenders hedging their borrower's rate locks? It is
still up for debate, but it is definitely a concern in the
industry well summarized on page 4 in this letter from Wells
Fargo to the SEC, FDIC, etc.: http://www.sec.gov/comments/s7-41-11/s74111-288.pdf.
Over
the years I have lost track of the org chart for RFC, GMAC,
GMAC/Ally, ResCap, and so on, although I know that I have coffee
mugs from several of them. But this could be big news: "Ally will cease
underwriting and trading mortgage-backed securities at its
broker-dealer and dismiss most of its 33 traders and
analysts." Here is the complete story: http://www.bloomberg.com/news/2012-04-09/ally-broker-dealer-unit-winds-down-mortgage-related-activities.html.
There
is a lot going on over in Washington and Oregon. First, Washington Federal will
acquire South Valley Bancorp (OR) for stock and a cash
earn-out up to a maximum of approximately $39 million based on
collections of a specific pool of assets. And sparkling wine
corks were popped at Mountain
Pacific Bank (WA) when it announced regulators have terminated
a C&D with the bank from three years ago.
How about some
investor/lender updates from the last few weeks. As
always, it is best to read the actual investor bulletins – information provided here
is meant to show trends rather than timely detailed specifics.
First,
the FHA has made a clarification to the Frequently Asked
Questions (FAQ) on Mortgagee Letter 2011-11 which can be found
at http://portal.hud.gov/hudportal/documents/huddoc?idúQsML201111.pdf.
It focuses on the definition of “Net Tangible Benefit”: It is
either a 5% reduction to the P&I of the mortgage payment
plus the annual MIP, or refinancing from an ARM to a fixed rate
mortgage in accordance with the conditions in the “net tangible
benefit” matrix. (Reducing the term of a mortgage is acceptable
on a streamline refinance if the new mortgage meets this net
tangible benefit test.)
One
policy that was mentioned about 10 days ago appears to be
unfounded: “The FHA has updated loan guidance to state that rental income paid by a
family member is not an eligible source of funds when taking
out a loan on a converted primary residence.” I can’t find the
source of this – I don’t make this stuff up! – and apologize
for any confusion that this may have caused.
More
HARP 2.0: the DU Refi Plus program at Kinecta is expanding.
Price adjustments are now available on Kinecta’s daily Rate
Sheets, and the updated overlay matrix has been updated as well.
Kinecta reminded lenders that, although it will accept a
Property Inspection Waiver in lieu of an appraisal, the file
must include evidence that the property is not a condo, co-op
hotel/motel, timeshare segmented ownership project, a houseboat
or any other property type ineligible for Fannie loans. Lastly,
in accordance with Fannie’s recently modified regulation
B7-3-04, Hazard Regulation Coverage for Units in Project
Developments, Kinecta changed its coverage requirements for
condo and PUD units. Where previously it required these
properties to have 20% coverage, Kinecta is now requiring
insurance policies that cover 100% of the replacement cost of
the unit’s interior as determined by the insurer. If the
HOA/Master/Blanket policy covers 100% of all common, exterior,
and interior insurable areas, the borrower doesn’t need to have
insurance for the individual unit; if not, the borrower must
have full walls-in coverage.
On HARP 2.0, Everbank
and Interbank are
enhancing their relevant products to feature finance with
unlimited LTV, and Guild
and Mountain West
Financial revised their DU Refi Plus guidelines.
A
few weeks ago, in the wake of the recent tornado activity in the
Midwest, and tornadoes in Texas, Flagstar is requiring
properties in several areas to be re-inspected and deemed
“satisfactory” before being granted Final Prior to Close
status. The requirements apply to all properties, including
those that did not require an appraisal. All FHA, VA, and USDA
Rural Housing loans underwritten by Flagstar now require
borrowers to have FICO scores of at least 640. For borrowers
with scores between 620 and 639, their loans must be locked on
or before March 29th and must disburse on or after May 11th. And
following the HARP enhancements, Flagstar is introducing the
Fannie Mae DU Refi Plus II and modifying the Freddie Mac Relief
Refinance II.
Wholesaler Mountain West Financial now requires the most recent
tax transcripts
available (in this case, the 2011 IRS Transcripts) upon
receiving a 4506-T executed by the borrowers, regardless of the
AUS Findings income guidelines. Loans that receive a DU Approve
or an LP Accept should have the tax transcripts for the number
of years of income documentation filled in on the DU Findings
Report or LP Feedback certificate. The full requirements depend
on the status of the borrower’s tax return; contact MWF for
details. MWF has issued clarification for the Monthly Income,
Assets and Liabilities, and Details of Transaction sections (V,
VI, and VII, respectively) of the Uniform Residential Loan
Application (URLA) on Streamline refinances. Lenders are also
reminded that the URLA should be signed by the borrower when the
application is made.
Before the case assignment order date of an FHA or VA ARM loan
rolls around, originators
are required to ensure that the borrower has received the
Consumer Handbook on Adjustable Rate Mortgages (CHARM) and
that this has been documented via a completed acknowledgement
form. FHA loans will require a completed 92900A form in
addition to the acknowledgement form, which should be signed and
dated by all the borrowers; VA loans will require a completed
18-2602 form in place of the 92900A. This protocol goes into
effect on Monday, April 9th.
The VA has updated
guidance to indicate that, although employment of less than 12
months is not considered stable and reliable, it may be
considered so if the employer’s evaluation provides evidence
that suggests a high likelihood of the borrower remaining at the
current place of work. In a case where the borrower holds a
skilled position (nurse, lawyer, paralegal, and computer systems
analyst are all cited as examples), training, education, and
special skills are also taken into account.
USDA Refinancing is
now available for Guaranteed USDA loans with or without an
appraisal that were closed by Mountain West Financial.
Interested buyers, apart from meeting the current income
requirements, must live in a rural area that is eligible or was
eligible at the time of the original loan closing, have no late
payments for the past 12 months, and have a FICO score of 620 or
over. Also on offer are rate term refinances with an appraisal.
There isn’t much to talk
about with interest rates. After the early close Friday,
Monday was a snoozer of a day. Per ThomsonReuters, buyers
outnumbered sellers, volatility dropped, and overall mortgage
banker selling was about half of what it has been. Agency
mortgage security prices did a shade better than Treasury prices
– probably due to the drop in supply. Today we have the first
leg of this week's supply: $32 billion in 3-year notes, but
aside from that there isn’t much moving rates. Yesterday we had the U.S.
10-yr T-note close at a yield of 2.04%, and in the early going
we find it unchanged – as are MBS prices. So don’t look
for much change on rate sheets today.
Here’s a “thought of the day” for Libertarians out there:
The
food stamp program, a part of the Department of Agriculture, is
pleased to be distributing the greatest amount of food stamps
ever.
Meanwhile, the National Park Service, also part of the
Department of Agriculture, asks us to "Please do not feed the
animals" because the animals may grow dependent and not learn to
take care of themselves.