FHA officials first asked for the servicing authority back in June, but the request has gone nowhere. Fannie Mae and Freddie Mac already have transfer authority.
A BuckleySandler lawyer reached into Zen lore to make his point. If a tree falls in the forest and no one hears it, does it make a sound? he asked. Similarly, Starting in 2014: If a lender complies with ATR/QM but cannot evidence it, has the lender complied?
The drop in warehouse commitments mirrored, somewhat, the fall-off in residential originations, which declined almost 19 percent in the third quarter, according to figures compiled by Inside Mortgage Finance.
Wells, Bank of America and JPMorgan Chase accounted for a combined 44.7 percent of the $517.75 billion in bank HELOCs outstanding at the end of the third quarter.