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May 28, 2012: Minority numbers; CFPB expansion; investor/vendor updates; don't forget why we have a holiday today
Rob Chrisman
The
world is a’ changin’, and who better to help us keep track of it
but the U.S. Census Bureau. It turns out that 50.4% of
our nation’s population younger than age 1 were minorities as
of July 1, 2011. This is up from 49.5% from the 2010
Census taken April 1, 2010. A minority is anyone who is not
single-race white and not Hispanic. The population younger than
age 5 was 49.7% minority in 2011, up from 49% in 2010. There
were 114 million minorities in 2011, or about 37% of the U.S.
population. (In 2010, it stood at 36%) There were five
“majority-minority” states or equivalents in 2011: Hawaii (77%
minority), the District of Columbia (65%), California (60%), New
Mexico (60%) and Texas (55%). No other state had a minority
population greater than 46% of the total.
When
I was in college, there were “The Big 8” accounting firms:
Arthur Andersen, Arthur Young, Coopers & Lybrand, Ernst
& Whinney, Deloitte, Haskins and Sells, KPMG (formed by
merger of Peat Marwick International and KMG Group), Price
Waterhouse, and Touche Ross. (That’s always a good trivia
question when a bunch of liquored-up ex-yuppies get together.)
There’s been another consolidation in accounting, with J.H. Cohn and Reznick
Group, both top-20 accounting firms in the U.S., announcing
plans to combine in September if things go as planned. The
firms have a fair number of clients in the real estate and
mortgage industries.) If it goes through, the new firm will
become the 11th largest accounting firm in the country with more
than 2,000 employees, 280 partners, 25 offices, and combined
revenues of more than $450 million.
Not
wanting to be left out of the headlines, way out west, in San
Francisco, the CFPB is
opening up a regional office to cover 17 states, headed up
by Edwin Chow, Western Regional Director. On June 11th
he will be discussing all the aspects of the CFPB – at least the
ones he’s allowed to discuss – at the Sacramento meeting of
CAMP (California Association of Mortgage Professionals).
If you wonder where a division head of the CFPB comes from, Mr.
Chow was a former deputy regional director with the OTS. The
event goes from 10AM -12PM: “Find out what you need to know to
stay in business in 2013.” For questions visit the CAMP website
or contact John Kaempfer at jkaempfer@comstockmortgage.com.
(For
anyone
unclear as to what the CFPB is, the bureau will take over the
regulation of consumer financial products and services - such as
mortgages, debit and credit cards, and checking and savings
accounts - from other federal regulators. It also will gain
powers over certain nonbank entities that are largely
unregulated, such as payday lenders, debt collectors, check
cashers, credit-reporting agencies and private student-loan
companies. Banks will continue to be regulated for safety and
soundness by the Federal Reserve, Federal Deposit Insurance
Corp. and the OCC. But any mortgage company who thinks that they
can avoid a CFPB just because it doesn’t do enough volume could
be in for a surprise.)
And
yes, the lender/agency/investor
news continues, and here are some recent changes. As
always, it is best to read the actual bulletin, but this will
give one a flavor for what is happening out there. In no
particular order…
Stonegate
Mortgage
announced the addition of five Regional Sales Directors to its
recently established Correspondent Financial Institutions
channel. Susan Gladden (Great Lakes), Tony Nienas (North
Central), Sean Marr (Southeast), Patrick Benoist (Midwest), and
Wendy Mack Dumas (Atlantic) will be focused on banks and credit
unions in their territories. (Stonegate services loans and
acquires loans on a wholesale basis.)
A few brief Fifth Third HARP 2.0
updates that went into effect on May 14th: the maximum LTV for
DU Refi Plus and HASP Open Access loans has been changed to
105%, while the CLTV and HCLTV are still unlimited. Non-Fifth
Third to Fifth Third loans are no longer permitted to transfer
mortgage insurance, and loans already registered or locked
before the May 14th deadline will continue with the previous
pricing adjustments.
The pricing adjustment for Fifth Third Agency Jumbo Fixed
30-year loans has been changed from -0.875 to -0.500.
Streamline loans that are refinancing an FHA loan that was
previously endorsed on or before May 31, 2009 will be subject to
a revised Upfront Mortgage Insurance Premium (UFMIP) and Annual
MIP. The new UFMIP of .01% and the new Annual MIP of 55 basis
points will affect loans with case numbers assigned on and after
June 11, 2012. Fifth Third cautions that case number requests
for FHA loans over $625,000 received by June 4th will be handled
as efficiently as possible, but that there’s no guarantee that
they will be processed by the June 11th deadline.
Fifth Third wholesale clients are reminded that the “transfer
notice” from the previous lender needs be included in the loan
submission in order to transfer an FHA case number; the original
FHA case number should be included as well. To transfer an FHA
case number to another lending institution, the loan must be
withdrawn or denied and the Fifth Third FHA case number transfer
request cover sheet emailed to wholesale.fhacasenumberrequest@53.com.
Flagstar has reduced
the price adjustment on Fannie Mae Cooperative Property Program
loans from -0.500 to -0.250, which went effect for loans locked
on or after May 14th.
When creating or updating a Quality Control or Police and
Procedures plan, Flagstar clients are reminded that they need to
include a verification process that will guarantee detection if
the company or any of its officers or employees are restricted
by a federal or state agency, e.g. being debarred or suspended
under a Limited Denial of Participation action.
There are a number of recent updates to the Flagstar
Conventional Underwriting Guidelines, the first of which
addresses material errors on credit reports that negatively
affect the risk analysis of the AUS. It is necessary in these
circumstances to update the borrower’s credit and obtain new AUS
findings. The guide has also been updated to say that the
number of mortgage inquiries a borrower has made will be
considered and could result in a denial, applicable to both FHA
and Conventional loans.
Flagstar will not approve and/or purchase any loan with an
unexpired right of redemption except in cases where the purchase
agreement, title, and appraisal all list the same seller who is
the original mortgagor; the title may show lis pendens notices
from the mortgagee or bank, and the purchase contract may
indicate a short sale.
As of May 21, 2012, loans submitted to Flagstar through
Freddie’s Loan Prospector will not be considered eligible to use
the cash-out proceeds from the subject refinance transaction as
reserves.
Due to investor deliberations, Guild is suspending
the USDA Streamline Program for loans that include financing of
closing costs. This doesn’t affect loans based on current
principal balance and the guarantee fee.
GMAC Correspondent
clients should be aware that additional due diligence
requirements apply if a borrower’s source of funds for the down
payment is from a state in the Balkans, Belarus, the Cote
d’Ivoire, Cuba, the Democratic Republic of the Congo, Iran,
Iraq, Lebanon, Liberia, Libya, Myanmar, North Korea, Somalia,
Sudan, Syria, or Zimbabwe. If the source of the assets is from
one of these sanctioned countries, the loan must be reviewed on
a case by case basis to address potential OFAC violations (full
details of the OFAC Sanctions Programs are listed on the
Department of Treasury’s website: http://www.treasury.gov/resource-center/sanctions/Programs/Pages/Programs.aspx.
Mountain West Financial
notifies brokers that, because the California FHA is presently
taking about three weeks to review loans that have been
submitted to them, they should move from CHDAP loan approval to
a PTF condition. This is provided that all other PTD conditions
are signed off and there is less than 1% difference between the
income being used for qualifying and the income limits. To
ensure efficient processing, the document order form should
clearly state the month for which the documents are being
drawn. Loans with documents that have been drawn in the current
month are only permitted to carry over the 7th of the next
month, and any loans that require a re-draw are subject to a
fee. MWF reminds brokers that CALFHA does not permit a
non-purchasing spouse or other party to be listed on the Deed or
Title; the title must be vested and remain in the purchasing
borrower’s name only. And
the minimum FICO score for all FHA and VA property flips has
been changed to 640, which is effective immediately for all
relevant MWF loans.
The Citibank
Ineligible Originator List has been updated and can be found in
the elfno section of the Correspondent website (http://app.communications.citimortgage.com/e/er?s53&lid9&elq1cce85addd744585b70201ae3db40d1d). The
Appraiser
Monitor/Ineligible List is also updated quite frequently and can
be found in the same section of the Correspondent site.
Citi raises the issue of inconsistencies between the borrower’s
address provided by a creditor from the borrower’s application
and the address listed on the credit report. Correspondent
clients are reminded that they are required to review and
resolve the discrepancies. Both Address Discrepancy Alerts
(where the address on the application is a variant of the
address in the credit history) and Address Mismatch Alerts
(where the address doesn’t show up on the credit report) must be
addressed, and underwriters are encouraged to rely on supporting
documentation rather than borrower explanations.
Instead
of the usual joke, it is good to take a moment and remember why
we observe this holiday. Memorial
Day, originally called Decoration Day, is a day of remembrance
for those who have died in our nation's service – not for
soldiers or veterans in general. While Waterloo N.Y. was
officially declared the birthplace of Memorial Day by President
Lyndon Johnson in May 1966, it's difficult to prove
conclusively, and seems to have originated in many places around
the country. In the 1860’s small ceremonies were being held to
honor those that died in the War Between the States, and in 1868
General Logan, national commander of the Grand Army of the
Republic, issued a proclamation (“General Order No. 11”).
Memorial Day was first observed on May 30 1868, when flowers
were placed on the graves of Union and Confederate soldiers at
Arlington National Cemetery. The first state to officially
recognize the holiday was New York in 1873. By 1890 it was
recognized by all of the northern states. The South refused to
acknowledge the day, honoring their dead on separate days until
after World War I (when the holiday changed from honoring just
those who died fighting in the Civil War to honoring Americans
who died fighting in any war) and it is now celebrated on the
last Monday in May. (Several southern states use other days –
1/19, 4/26, 5/10, or 6/3 - as a separate day for honoring the
Confederate war dead.)
Some
people
think the day is for honoring any and all dead, and not just
those fallen in service to our country. Unfortunately
traditional observance of Memorial Day has diminished over the
years, and some seem more focused on having a day off. Please
don’t forget its purpose.
If
you're interested, visit my twice-a-month blog at the STRATMOR
Group web site located at
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