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Sep. 11, 2012: Redwood's new deal; revamped repurchase plan; thoughts on importance of QC; agency updates
Rob Chrisman
Is
it easier to finance 500 non-owner loans than it is 5? It is
kind of looking that way: http://www.reuters.com/article/2012/09/04/us-real-estate-banks-idUSL2E8K46VK20120904.
But
speaking of lots of loans, and lost in the chatter about the
Treasury saying it will sell about $18 billion of its AIG
stock holdings, reducing its ownership stake from 53%
currently to about 20% after the sale and making a nice
profit, some of the buzz in the rating agency session at
yesterday's conference in Dallas focused on Redwood
Trust's new non-agency deal. Here are is the summary: http://www.bloomberg.com/news/2012-09-10/redwood-to-sell-securities-backed-by-313-2-million-of-mortgages.html.
And Redwood share price, like many other mortgage related
stocks (banks, REIT's, servicers, etc.) is doing pretty well:
http://community.nasdaq.com/News/2012-09/redwood-trust-momentum.aspx?storyid1358.
And
regarding loans in general, I received this note, "Rob, my
borrowers ask me about bank lending. In this environment, can’t
banks make money even falling off a log?” My opinion is
that no, they can’t – it still takes work. Sure, the spread
right now between their cost of funds (easily less than 1%)
and where their loans are (an easy guess is where residential
or commercial loans are right now) is good. But much of the
cash they’re earning now is being socked away for a rainy day.
There are significant changes to bank capital
structure under Basel III which may or will come into play –
what if it is too expensive for banks to hold many residential
mortgages being originated now? Regulatory changes have
muddied the water so much, investors can’t tell what sort of
return they will get on their investment so capital flows have
slowed to a trickle. Add to that a Presidential election year
and an uncertain outlook and you have all the pieces of a very
jumbled and confusing situation that has too much risk in
motion to properly calculate bank income into the future.
It seems, however, that even though Fannie and Freddie are
going after old repurchases with lots of vim and vigor, the
FHFA is going to revamp repurchases. "Under the new
rules, the two taxpayer-owned companies won’t force lenders to
repurchase defaulted loans if the borrowers have made 36
months of consecutive, on-time payments. Banks will be
protected from buyback requests after only 12 months of
payments for certain types of loans, such as those originated
under the federal government’s Home Affordable Refinance
Program." Here more: http://www.businessweek.com/news/2012-09-10/fannie-mae-and-freddie-mac-to-begin-new-loan-review-system.
Whoever
controls the information, and can mine the data, is going to
come out ahead, right? Just think of all the data that
entities like MERS, title companies, the FHFA through Freddie
& Fannie, and so on hold. There exists, outside of those
entities just mentioned, “a computerized compendium of
millions of housing transactions.” It is a decade’s worth of
residential information from across the country, and some
think it might shed some light on historical mortgage
information that could be used to correct issues in the
future. “The system is an outgrowth of work done by a New York
investment manager, Thomas Priore. In the boom years, his
investment firm, ICP Capital, navigated the dangerous waters
of collateralized debt obligations via an investment vehicle
called Triaxx…. Triaxx’s technology came to light only last
month, in court documents filed in connection with the
bankruptcy of Residential Capital. ResCap was the mortgage
lending unit of GMAC, now known as Ally Financial. As an
investor in mortgage securities, Triaxx gained access to a lot
of information about loans that were pooled, including when
those loans were made, where the properties are and how big
the mortgage was, relative to the property’s value.” Here is
the scoop: http://www.nytimes.com/2012/09/09/business/how-to-find-weeds-in-a-mortgage-pool-fair-game.html?_r1.
It
is definitely a different environment now then it was then for
lenders. David Green, the president of quality control's The
StoneHill Group, writes, "Rob, among lenders out there
we are seeing confusion regarding Fannie and now Freddie’s
pre-funding QC requirements and recommendations. The extent
of the review, documenting and establishing action plans based
on the results of the reviews and incorporation of the review
into a company’s Quality Control plan; all of these areas
appear to be open to interpretation, based on who you speak
with. We are also seeing many lenders still struggling with
Fannie and now Freddie’s Loan Quality Initiative (LQI);
establishing a compliant QC plan based on the quality
initiative, as well as the scope of review based on the level
of LQI. Whereas LQI 1 encompasses all loan types, including
FHA and VA, LQI 2 is generally based on conventional loan
product. Many Lenders are still unclear of the levels of LQI
as well as the initiative."
David continues, "Senior management's involvement and action
around findings is required once the QC reviews are complete.
A formalized plan, involving Sr. Management, to review and
remediate findings discovered during a Pre-Funding and/or
Post Close Quality Control review is necessary for a
successful Quality Control Program. Documentation around
findings and resolutions as well as updating of the Lenders QC
plan are an integral part of the process. Clients often ask
about selecting a defect rate. While this is left up to the
lender, selecting a defect rate that is relative to the
lender's business model is imperative. Defect rates should be
realistic in nature and should be established for both
significant and insignificant ratings. Defect rates should not
be set to a standard that is not reasonably obtainable.
Lastly, a lenders commitment starts at the top and filters
through to all employees of the company. A "Commitment to
Quality" statement outlining a lenders quality initiative,
requirements and agreeance to adhere to this commitment should
be executed by all employees. This brings awareness and a
level of understanding to all involved that the company is
committed to Quality." (If you'd like to reach David, write to
him at dgreen@stonehillgroup.com.)
Well, the agency, investor, and lender updates just keep
coming. It is hard to keep up, and I squeeze them in, space
permitting. As always, it is best to read the actual bulletin,
but these will show you the trends.
The National Association of Mortgage Brokers is presenting
a webinar on the recent regulatory developments surrounding
disparate impact claims and mortgage loan originator
compensation on Thursday, September 13th. Led by a
team from BuckleySandler LLP, the training will also discuss
the implications of the business model for wholesale lenders
and brokers. The event is free for NAMB members thanks to the
sponsorship of SunTrust Mortgage, Franklin American Mortgage
Company, and Premier Nationwide Lending. See
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