FBI Investigating Flood Maps; Jumbo Production Forecast Falls; Proposed AMC Legislation
heading to Wisconsin for a few days, over the weekend I called The
Bellagio to find out the betting lines on the PATH Act, Johnson-Crapo,
Corker-Warner, and now Maxine Waters' lender co-op bill. They were all
too busy watching basketball games to bother, but the odds against reconciling the proposals on Fannie & Freddie's fate in an election year are not to be underestimated.
(One person wrote to me Friday, calling the players a "hodge-podge of
politicians, most of whom know little about the lending business or the
function of Fannie or Freddie, trying to make a name of themselves with
their constituents.") Ms. Waters' bill's nuances can be found here.
One thing we know for sure is that some companies are continuing to hire. Cole Taylor Mortgage (CTM) continues to actively expand retail branches and wholesale lending relationships throughout
the U.S. CTM is a division of Cole Taylor Bank, a Chicago-based bank
founded in 1929, that originates residential loans in 44 states plus
Washington, D.C. In retail, CTM
provides centralized IT and accounting support, dedicated retail
operations, training, and marketing services at no cost to the branch. CTM is specifically looking to grow retail branches in the Texas triangle and Southern California markets. Interested branch managers and loan officers in any market should contact Mike O'Brien at mobrien@ctmtg. com. Or, if you're looking for a wholesale lending opportunity, click here to find a local Area Manager and get started. Cole Taylor Mortgage is an Equal Housing Lender and Member FDIC, NMLS#493677.
And on April 3 Carrington Mortgage Services is hosting another career webinar.
"Join Carrington Mortgage Services and Ray Brousseau, EVP Mortgage
Lending for a Career Webinar with Carrington Mortgage Services. Discover
the opportunities for loan officers, managers, and branches." By the
way, Carrington just announced new loan products down to 550. "Great
compensation, benefits and a wide variety of programs that can help you
take your performance and sales to the next level." There are morning
and afternoon sessions on Thursday.
Flood insurance legislation has been in the news, and now the FBI is investigating flood maps. Darren M. contributes, "Interesting recent research into FEMA flood map changes." Thanks Darren!
There has been a lot of appraisal news in recent weeks, the most important perhaps being that six
government agencies issued a proposed rule that would implement minimum
requirements for state registration and supervision of appraisal
management companies (AMCs). Just so we're clear, an AMC is an
entity that serves as an intermediary between appraisers and lenders and
provides appraisal management services. In accordance with section 1124
of Title XI of the Financial Institution Reform, Recovery, and
Enforcement Act of 1989, as added by section 1473 of the Dodd-Frank Wall
Street Reform and Consumer Protection Act, the minimum requirements in
the proposed rule would apply to states that elect to establish an
appraiser certifying and licensing agency with the authority to register
and supervise AMCs.
proposed rule would not compel a state to establish an AMC registration
and supervision program, and there is no penalty imposed on a state
that does not establish a regulatory structure for AMCs. However, an AMC
is barred by Section 1124 from providing appraisal management services
for federally related transactions in a state that has not established
such a regulatory structure. Under the proposed rule, participating
states would require that an AMC register in the state and be subject to
its supervision, use only state-certified or licensed appraisers for
federally related transactions, such as real estate-related financial
transactions overseen by a federal financial institution regulatory
agency that require appraiser services, require that appraisals comply
with the Uniform Standards of Professional Appraisal Practice, and so on
- over a dozen more requirements.
proposed rule would provide participating states 36 months after its
effective date to implement the minimum requirements. It certainly has
some heavy-weight backers: the Office of the Comptroller of the Currency
(OCC), the Board of Governors of the Federal Reserve System, the
Federal Deposit Insurance Corporation (FDIC), the Consumer Financial
Protection Bureau (CFPB), the Federal Housing Finance Agency (FHFA), and
the National Credit Union Administration (NCUA). The public will have
60 days to review and comment on the proposal. Publication of the
proposal in the Federal Register is expected shortly.
Mike Ousley with Direct Valuation Solutions
writes, "In the original Dodd-Frank Act there were provisions that
generally followed the new proposed rule for participating states to
register AMCs, however, it was generally perceived that the states had
36 months to establish a supervision program that would comply with
Dodd-Frank. What's interesting about this proposed rule is the
following: 'The proposed rule would not compel a state to establish an AMC registration and supervision program, and there is no penalty imposed on a state that does not establish a regulatory structure for AMCs. However, an AMC is barred by section 1124 from
providing appraisal management services for federally related
transactions in a state that has not established such a regulatory
structure.' One could theorize that certain state appraisal
regulatory agencies, many that are run by independent appraisers upset
that AMCs even exist, would push to have their state opt out of AMC
regulation and supervision, thus barring AMCs from all federally related
transactions within their state. Lenders active in those states that
had relied upon AMCs to manage the appraisal assignment and management
process would then be forced to either establish an affiliate AMC and
deal with the CFPB rules on affiliate charges as related to qualified
mortgages and the 3% points and fees calculation, or contract directly
with appraisers within those states by utilizing a platform such as
Direct Valuation Solutions to assign, track and deliver appraisals for
federally related transactions. The AMCs that fought the original
registration and supervision by states may now be forced to actually
embrace and push for more state level oversight of their activities in
order to not get left out entirely."
Mike Simmons with Axis Appraisal Management
wrote, "Kudos for noting one of the standout provisions that allows
states, without penalty, to opt out of establishing an AMC registration
and supervision program. What's noteworthy is that while those states
that elect that path won't be penalized, their citizenry will. Since AMC's will be proscribed under Section 1124 from providing management services,
borrowers will either be limited in their choices of loans and lenders,
or face increase costs from having a shorter list of lenders invest in
building and managing their own panels in what will be a small number of
states. Since there are 38 states that currently have AMC laws, perhaps
this an elliptical way for the rule to encourage 100% participation?
Given the fact that states benefit financially from the fees levied on
AMC's for maintaining such oversight, and that they can and often do
impose higher standards versus the new federal rule, we'd be surprised
at less than full participation. For those of us who truly embody
service in this era of increased regulation, the contribution we add to
lenders, appraisers, consumers and their communities is both significant
what company would rather do 4 loans for $200k each or 1 loan for
$800k? It is easy to make the argument that doing one loan for the same
amount as the others combined requires less time and cost, and limits
the odds of future problems. That debate aside, independent
mortgage LOs continuing to "complain" about the rates offered by banks
like Wells Fargo on their jumbo loans - but hey, if I am a bank, I'd
rather only service one $800k loan than four $200k loans with lower
rates. And research staffs are cutting their estimates of the total
jumbo biz for 2014, which is really too bad for the scores of hedge
funds and money managers investing money into thinking they're going to
be next coolest thing in jumbo loans. "Demand from banks for jumbo loans
prompted JPMorgan Chase & Co. analysts this month to lower their forecast for 2014 issuance of non-agency, or private label, securities
to $5 billion to $10 billion, from about $20 billion." And just to
bring you up to date, Redwood Trust issued a new MBS for $342 million.
Let's take a look at some upcoming events, promotions, and training modules that might be of interest.
First, the Colorado Mortgage Lenders Rocky Mountain Expo is coming up in a couple weeks - here's the link to the event home page.
Michigan's Northpointe Bank announced that Wendy Minter has joined the bank as Director of Correspondent Lending. Wendy has over 20 years of Mortgage Banking experience in both correspondent and wholesale lending and will be expanding Northpointe Bank's correspondent customer base nationwide (it is already buying loans in 45 states). To learn more about Northpointe Bank's correspondent program, contact Wendy at wendy.minter@northpointe. com.
For IT and compliance folks, on April 8th Byte Software will be hosting an in-depth webinar exploring the differences between BytePro Standard, BytePro Enterprise and BytePro Online. BytePro
Enterprise employs Microsoft SQL Server to satisfy the security,
compliance, scalability and flexibility requirements of larger
organizations. This webinar will outline the functionality and advantages that each system offers, including features such as the enhanced visibility of your compliance process and a comprehensive audit trails to track changes.
Settlements, Inc., a data intelligence and risk analytics company for
the mortgage industry, announced that the Honorable Kenneth Donohue,
former Department of Housing and Urban Development (HUD) Inspector
General, has joined its Industry Leader Advisory Board. Secure Settlements, Inc.
is "the first company to offer a standardized risk management process
and information database of fully risk-assessed mortgage closing
professionals that protects both consumers and lenders, reducing fraud
and ensuring that federal regulatory requirements are met. The SSI
process delivers the most advanced closing fraud risk analysis in the
industry and helps lenders meet the risk management expectations for
third-party risk assessment of vendor relationships, as outlined by
CFPB, OCC, HUD, FDIC, Fannie Mae, Freddie Mac and the National Credit
First Look Appraisals,
a leading national appraisal management company, announced the
completion of a software integration that gives all users of Ellie Mae's
Encompass mortgage management solution the ability to order appraisals
directly from their software. "The
integration eliminates common delays and data entry errors, and
provides loan originators with the highest level of dedicated service
while keeping them informed during every step of the critical appraisal
process. With First Look's solution, loan originators don't need to
rekey any data from the loan file, so data entry mistakes that typically
cause delays in the appraisal process are eliminated."
we are, on the last day of the first quarter, staring at a new week of
economic news - and who knows what might happen overseas! Today is the
Chicago Purchasing Manager's Survey, tomorrow is the ISM Manufacturing Index
(from purchasing managers of 300 manufacturing firms about general
trends) and Construction Spending, Wednesday are the ADP employment
numbers (always of questionable predictive ability for Friday's
employment data) and Factory Orders. Thursday we'll find have Initial
Jobless Claims and some trade balance figures. On Friday, April 4th,
we'll have the usual series of employment data, arguably the most
important U.S. data of the month. For numbers in the early going, the 10-yr closed Friday at a yield of 2.71% but this morning is up to 2.75% and agency MBS prices are worse about .125.
of some humor today, let's swing the other way. Besides a lot of us
driving, many of us have kids either driving or riding their bikes on
the roads. Late last week The National Safety Council released its
latest injury and fatality statistics. Did you know that over 25% of car accidents are linked back to cell phone usage? Here you go.