New LO Referral Service; HARP Expansion Update; MBA Comp Survey; Possible HMDA Change Info
idea how much Realtors make?" I don't know, and asking someone their
income isn't always the wisest of moves, especially on a first date. But
the NAR takes the guesswork out of it by publishing median (half above,
half below) incomes, ages, and so on, of its members in its Membership
And in this year of industry transition here is an interesting approach: a service that helps one find reputable, vetted LOs outside of your area.
"Have you ever had a request for mortgage financing outside your
licensed area and wanted to be sure they got the best service (without
losing your customer)? Good news: now you can easily and confidently make referrals anywhere in the country! Premier Mortgage Network, LLC
sought out elite mortgage professionals with a reputation for world
class customer service and thoroughly vetted them to ensure they are the
best of the best. Confidently send your referrals to an outstanding
mortgage professional that will provide the same exceptional service you
do (you'll even get updates)! to register and gain access to this network. There is never any cost to you or your clients to use this service. If you have any questions, please contact Julie Diamond at firstname.lastname@example.org."
MBA also continues to gather information, and came out with its latest
compensation benchmarking study. "MBA's benchmarking studies offer
mortgage companies better business intelligence when making important
personnel and operational changes to adapt to this regulatory climate.
For ten years, MBA has recommended the annual Residential Mortgage Banking Compensation Survey Program to
its members as they develop and implement their individual compensation
strategies. This year's program includes the 2014 Residential
Compensation Survey that profiles more than two hundred positions across
all mortgage-related lines of business and functional areas. Among the
elements covered: base salary, cash bonus, total cash, commissions,
overtime, total compensation and long-term/deferred awards. Reports
include scoping factors such as geographic region, number of employees,
revenue size and total loan volume. In addition, productivity data is
collected and included in the report at the individual level (i.e. loan
officer loan production); three specialized compensation benchmark
products that are focused on production, servicing and
corporate/executive functions; a 1½ day MBA Human Resources Roundtable
in September. Open to participants in the survey, this interactive
workshop offers a unique opportunity for attendees to network with
peers, while analyzing the latest in compensation benchmarking data and
human resource trends. Results from the 2014 Residential Compensation
Survey will be presented. Registration and participation in the program
is required in order to receive the results and MBA members receive a significant discount off the regular survey pricing. The survey questionnaires will be sent in March. Publication of the survey is anticipated for August 2014. Please complete the registration form
today to secure your firm's participation in this program, or if you
have general questions, please contact Marina Walsh, MBA Research, at MWalsh@mba.org.
The MBA is definitely following the HMDA developments. But what do credit unions think of the CFPB's quest for more HMDA information? Here you go.
MBA sent out an update saying, "The CFPB began the process of revising
the Home Mortgage Disclosure Act (HMDA) rules to require lenders to
collect and report several new data elements. Some of these new data
elements are specifically required under Dodd-Frank. However, the Bureau is also considering requiring some additional data elements.
The CFPB is also considering changes to the collection rules to
streamline reporting and improve data entry. Finally, it is also
considering revising the reporting thresholds so all banks and non-banks
report if they make 25 or more mortgage loans in a year. A summary of
the data elements sought by the CFPB is here.
Notably, Dodd-Frank adds the following HMDA data elements (unless the
CFPB decides otherwise): total points and fees, and rate spreads for all
loans (not just HPMLs); risky loan features including teaser rates,
prepayment penalties, and non-amortizing features; the length of the
loan; expanded lender information, including a unique identifier for the
loan officer and the loan; property value and improved property
location information; borrower age and credit score.
CFPB is also considering requiring: mandatory reporting of reasons for
denial; debt-to-income (DTI) ratio; Qualified Mortgage status of loan;
combined loan-to-value (CLTV) ratio; automatic underwriting systems
results; additional points and fees information (including interest rate
- HMDA requires APR currently, total origination charges, Bona Fide and
Total discount points, risk-adjusted, pre-discounted interest rate);
whether loan has affordable housing deed restrictions; and manufactured
"As a first step in revising the rules, the CFPB has convened a small business review panel required under the Small Business Regulatory Enforcement Fairness Act (SBREFA) to
provide input on the changes under consideration, focusing particularly
on the burden these requirements would create. Over the next few weeks,
the CFPB will conduct several conference calls with the SBREFA panel
and an in-person meeting in Washington DC in early to mid-March.
Following the conclusion of the panel's work, the CFPB is expected to
issue a proposed rule. At least four members of the panel are employees
of MBA member companies and MBA is acting as a resource to industry
panelists. MBA believes that the new data collection requirements
present several important concerns that must be resolved to avoid undue
operational burdens and litigation risks-especially in light of HUD's
recent disparate impact rule. MBA also wants to ensure that consumer
privacy is not compromised under any new HMDA regime. MBA will raise
these and other issues in the rulemaking process. We are at the
beginning of what should be a lengthy process. Any
new HMDA rules are unlikely to require new data until 2016 at the
earliest. We will provide updates as this important process moves
"Rob, what do you hear about the government expanding HARP?
If they do, will we see another refi boom?" I hate to be the bearer of
bad news, but a story in Bloomberg last week filled us in. "HUD's
Donovan Confirms HARP Won't Be Expanded, FBR Says." "Now HUD has joined
the Treasury on doing nothing with regard to HARP, which makes it a bit more difficult for Watt to garner support for material changes."
"HUD Secretary Shaun Donovan made it clear yesterday at a Politico
event that his department. Will not push for HARP expansion, confirms
that no broadening of program should be expected, FBR analyst Ed Mills
writes in a research note. Donovan believes improving access to credit
for mortgage borrowers remains HUD's most important policy challenge.
Sees Wells Fargo's pursuit of 600-640 FICO FHA borrowers as positive
sign for credit availability. Donovan is cautiously optimistic about
FHA's finances; following last year's infusion of taxpayer money into
FHA, many in Washington concerned about its balance sheet."
Turning to some recent lender, investor, and vendor news...
Green Tree is
prohibiting the use of a Power of Attorney to execute documents for
cash-out refinances and Texas 50(a)(6) transactions. In addition,
lenders, affiliates of lenders, any employee of lenders or their
affiliates, loan originators, loan originators' employees, title
insurance companies, and real estate agents with a financial interest in
the transaction may not sign the security instrument or note as the
attorney-in-fact or agent under a Power of Attorney.
Tree has revised its guidelines to specify that leasehold agreements
pertaining to purchase transactions must not have any servicing
reporting requirement to the lessor, and the lender must not be required
to sign a subordination document. For
permanent financing on new construction, guidelines have been updated
to require that the LTV/CLTV be based on the appraisal, both in lot and
improvements, regardless of how long the borrower has held title to the
lot. The same calculation applies to cash-out refinances; in addition,
borrowers must have held title to the lot for at least six months prior
to the closing of the permanent mortgage.
Green Tree's updated underwriting guidelines, borrowers must have a
credit history sufficient to make a determination of creditworthiness
and a minimum of three open tradelines, each of which should be rated
and paid within the past 24 months. In cases where the borrower has
revolving debt that they wish to pay off for loan qualification, the
account must be paid in full and closed at or prior to closing. The
creditor should certify that the account is closed with no outstanding
transactions, and the borrower's source of funds must be documented.
Tree has revised its employment verification policy to require the
borrower's most recent account statement if the AUS returns an Approve
status and either a Verification of Deposit or the two most recent
consecutive monthly account statements in the case of a Refer status or
manual underwrite. FICO
guidelines have been relaxed, and instead of a minimum of two reported
credit scores, underwriters may use only one score if it is reported and
accepted by the AUS.
immediately for all Jumbo transactions, Green Tree is considering
borrowers who are re-entering the workforce to have stable employment if
they have been employed in their current job for six months or more and
if the loan file includes documentation of a two-year work history
prior to the absence.
revised its Conventional guidelines on condo/PUD flood insurance;
derogatory credit; and minimum borrower contributions when gift funds
are being used to align with those of the Agencies. For the FHA 203(b) loan program, the policy on gaps in employment has been updated to align with FHA guidelines.
First Community Mortgage has
launched its new Lender Paid Mortgage Insurance program, which offers
both Conforming and high balance loans with LTVs over 80%, and has
expanded its LP Relief Refinance program to allow LTVs from 105% to
Radian Guaranty has
released its December delinquency data, reporting $2.85bn in new
insurance and primary delinquent inventory as dropping from 62,556 loans
to 60,909 loans. There were 4,650 new delinquencies, which were offset by 4,104 cures, 2,084 paids, and 109 rescissions and denials.
noted yesterday, there is a decent line-up of economic news coming our
way this week. Inflation has not been an issue for many, many years, but
still analysts talk about it - especially when there isn't much else to
talk about. We'll have the monthly inflation reports: the Producer
Price Index (PPI) and its sibling the Consumer Price Index (CPI) out
Wednesday and Thursday, respectively. The minutes from the January 29
Federal Open Market Committee Meeting will be released on Wednesday, as
will Housing Starts. Its cousin Existing Home Sales will be released on
Friday. Throw in today's Empire Manufacturing, the Philly Fed, NAHB
Housing Market Index, Leading Economic Indicators, and Jobless Claims,
chocolate chips, mix well, and put in the oven at 375 for 12-15 minutes.
yield on the 10-yr Friday closed at 2.75%, which is where it spent much
of the week. In the very early going today we're at 2.73% and agency
MBS prices are a shade better.
It is imperative, through this 41 second video, to stay up on the latest Olympic sports. I don't think you'll be sorry.