Fraud Trends; Lenders One Weighs in on G-fees; HARP & Servicing Comments; Where Does Impound Income Go?
Baseball
fans will know the answer to this one: What's the difference between a hot dog
at Fenway Park and a hot dog at Yankee Stadium? Answer: You can get a hot dog
at Yankee Stadium in October.
Servicing
values directly impact mortgage pricing. If you'd like to add your two cents on
servicing, you can write to Servicing_Comp_Public_Comments@fhfa.gov.
FHFA
is requesting public comments on two alternative mortgage servicing
compensation structures. The proposed structures are the result of
work done under a Joint Initiative involving Freddie Mac and Fannie Mae (the
GSEs), FHFA, HUD, FHA, and Ginnie Mae. FHFA's goals are to improve service for
borrowers, reduce servicers' risk, and provide flexibility for guarantors to
better manage non-performing loans (NPLs) while promoting continued liquidity
in the To Be Announced (TBA) mortgage securities market. But the Joint
Initiative also seeks to develop options for compensating servicers that will
enhance competition and can be replicated in any future housing finance
structures that emerge under GSE reform. Mortgage News Daily notes that,
"Servicer compensation (Mortgage Servicing Right or MSR) is currently
decided by the originator setting the mortgage rate offered to borrowers in
terms of the spread above the par TBA price net of the guarantee fee that, when
combined with the other income derived from origination and servicing (late fees,
interest on escrow and payment floats) provides the servicer with an acceptable
risk adjusted return on capital. The spread charged in the mortgage rate
for origination and servicing is based on competition, expected costs, and the
expected returns of originator and servicer and should cover the expected costs
of servicing including servicing NPLs." But perhaps servicing companies
make too much on loans where there are no delinquency issues, and not enough on
loans where there are.
Freddie and Fannie, and the FHFA, have a lot going on. (How do you like that
for an understatement?) Not only are servicing values in play, but guarantee
fees are as well, along with revamping an ineffective HARP. The FHFA is trying
to conserve the assets of the GSEs and make them solvent, support a "stable and
liquid mortgage market," and provide maximum assistance to homeowners and
minimize foreclosures, "considering net present value to the taxpayer." One
doesn't do that over lunch one afternoon. For a more in-depth angle, you can
check it out.
"Dear
Miss Manners: Regarding loan servicing,
doesn't the interest earned on California impounds go to the borrower?
I thought it did. But then why do some (most) lenders still charge a .25
fee for no impounds?" Answer from a servicing expert: "That's a great
point. States that require the servicer to pay interest on escrows to the
borrower will have a lower base SRP in general. One could argue that if the
interest paid to the borrower equals the interest earned on escrows, those
loans with or without escrows would cash-flow equally. The rate earned on
escrows is obviously dependent on the servicer's business model and the
interest paid is dictated by state law... So a slight spread is potentially
available. Also, most lenders apply an aggregate level fee as the true
value of escrows ranges anywhere from .05 to .45 depending on state. A
rough guess is that the average value of escrows in California is about .10 while
the value of escrows in a state like Texas is about .45."
Lenders One is calling for the FHFA to
end volume discounts on Fannie Mae and Freddie Mac's guarantee fees, which Lenders One believes puts
small and medium sized lenders at a competitive disadvantage versus "The Big
Boys." G-fees have been in place for decades, and "in the old days" we'd stand
around at conferences and compare them, with the largest, most financially
sound lenders having the lowest and the riskier lenders having higher g-fees,
similar to riskier drivers paying more for car insurance. Currently the ten
largest customers of Fannie and Freddie paid an average g-fee of 23 basis
points in 2010, but seller/servicers ranked 11 through 90 paid 27 basis points.
This week
the commentary discussed HARP, and I
received input. "This issue with HARP could be that it will literally take an
act of Congress to make the necessary changes. The acts of Congress which
created the charters of Fannie and Freddie require the enterprises to buy
'investment quality' mortgages. That has always meant that the loans must
be made to borrowers with sound credit and (not or) secured by collateral
sufficient to repay the debt should the borrowers default. This is also
why MI is required for LTVs greater than 80%. Do you recall the
legal and political wrangling that occurred when Fannie and Freddie rolled out
their affordable products to 100% LTV and 103% CLTV? There were a lot of
lawyers inside and outside the GSE's, and their regulators, creating broad
opinions of the charters that allowed the expansion of risk to occur. The
same thing happened when HARP was originally rolled out. Now we are
clamoring for LTVs up to 150%? That's fine, but can you really argue that
a 150% LTV loan is backed by collateral sufficient to repay the debt?
That's why Fannie and Freddie can't just wave their magic wands to change the
program. It seems that any expansion of HARP may have to be resolved when
the Congress addresses the fate of the GSE's, and we all know what a political
football that is."
CoreLogic has announced the availability of its
2011 Mortgage Fraud Trends Report: a
look at over 10 million loan applications from the first quarter of 2005
through the first quarter of 2011. It is hardly the golden era for mortgage
lending. CoreLogic fraud experts predict that fraud-related U.S. residential
mortgage originations will total $7.4 billion in 2011, down from the estimated
$12 billion in mortgage fraud-related originations experienced by the industry
in 2010. (And yes, there are trends, so for example property fraud is up 262% - flipping and flopping - but identity fraud is
down 45%.) The dollar drop is nice, but it is primarily due to lower
mortgage origination volume in 2011. And it isn't time to let down your guard,
as "new fraud schemes are constantly evolving to infiltrate weaknesses and
vulnerabilities in lenders' fraud prevention programs," said a CoreLogic exec.
Per the firm, the five riskiest areas of the country for fraud-related originations
based on the first three digits of the ZIP code are Chicago, Ill. (606);
Washington, D.C. (201); Brooklyn, N.Y. (112); Atlanta, Ga.(303) and Jamaica,
N.Y. (114). (Jamaica? Nah, she wanted to...)
LO comp
plans do indeed change. Bank of Internet
sent out word to their clients: "Effective October 1st 2011 Bank of
Internet will be adopting a flat Lender Paid Compensation model. All fourth quarter
Wholesale Lender Paid Compensation plans will be moving to this new pricing
structure and will affect loans registered on or after the above date. Bank of
Internet will continue to offer the Borrower Paid Compensation model with no
changes or modifications at this time. All loans registered prior to October
1st will be processed under the Lender Paid Compensation plan previously
selected. As a result of this change no further action is required on your
behalf relative to your organizations Lender Paid Compensation selection."
Wells Fargo told its brokers that, "Areas
designated as a disaster by FEMA, or areas where Wells Fargo has required that
disaster policy be followed, require the appropriate appraisal documentation
(such as, but not limited to, Hurricane Irene and Texas wildfires) such as a
full interior/exterior appraisal. The Fannie Mae Property Inspection Waiver
(PIW) and Freddie Mac's Property Inspection Alternative (PIA), 2070/2075, and
2055/1075 are no longer accepted appraisal products. Wells' wholesale also
updated its Four Wells Fargo Home Equity (WFHE) policies: Declining markets, Undue
influence regarding reasonable and customary appraiser fees, Unacceptable
source of income and Maximum acreage eligible for WFHE financing. Check the
bulletin for specifics.
Thursday
was pretty quiet in the bond markets, some of which was attributed to a number
of participants being out for the Jewish holiday. Mortgage banker selling was
on the lighter side at between an estimated $1.5 and $2.0 billion - maybe they
sold everything earlier in the week. But the demand was there, and MBS prices
were up nearly .375 as the 10-yr T-note also improved .375 and dropped back to
1.96% near the close.
Today, the
last day to fund some of the high balance and Streamline locks, we've already
had some numbers. Personal Income was -.1% and Personal Spending was +.2%. The
PCE Price Index was +.2%. But the focus was on the personal savings rate, which
is 4.5% - the lowest rate since 2009. Later we have the Chicago PMI (Sep) and
final September Michigan Sentiment. It is easy to make the point that US debt
issues and European issues should carry more weight in moving the markets than
these lesser numbers. Regardless, in the
early going the 10-yr is down to 1.94% and MBS prices are about .125 better.
A man returns home a day early from a business trip. It's after midnight. While
en route home he asks the cab driver if he would be a witness, since the man
suspects his wife is having an affair and he wants to catch her in the act. For
$100, the cab driver agrees.
Quietly arriving home, the husband and cab driver tiptoe into the bedroom. The
husband switches on the lights, yanks the blanket back, And there is his wife
in bed with another man!
The husband puts a gun to the naked man's head.
The wife shouts, "Don't do it! I lied when I told you I inherited money.
HE paid for the Corvette I gave you.
HE paid for our new cabin cruiser.
HE paid for your Pittsburgh Steelers season tickets.
HE paid for our house at the lake.
HE paid for our country club membership, and HE even pays the monthly dues!"
Shaking his head from side-to-side, the husband lowers the gun.
He looks over at the cab driver and says, "What would you do?"
The cab driver replies, "I'd cover his 'rump' with that blanket before he
catches cold."
If you're interested, visit my
twice-a-month blog at the STRATMOR Group web site located at www.stratmorgroup.com. The current blog takes a look at Fannie &
Freddie & the FHFA, and the changes they have in the hopper. If you have
both the time and inclination, make a comment on what I have written, or
on other comments so that folks can learn what's going on out there from the
other readers.