The pending TILA/RESPA Integrated Disclosure (TRID) rule from the CFPB is going to raise the risk of losses for investors in U.S. residential mortgage-backed securities, according to a new report from Moody’s Investors Service. Currently, as Moody’s points out, RMBS trusts are liable for lender errors in calculating the finance charge, the annual percentage rate (APR) and certain other disclosures required by the Truth in Lending Act. However, they are not liable for errors on itemized settlement charges and other disclosures required by the Real Estate Settlement Procedures Act. Further, under the current regime, TILA and RESPA each require lenders to deliver both an initial and a final disclosure to consumers. “Whether an assignee can be liable for lender errors ...
Fannie Mae and Freddie Mac have found deep investor appetite for credit-risk transfer transactions, but their exploration of new structures may not get to the front-end tradeoff of deeper mortgage insurance for reduced MBS guaranty fees. During a panel session at last week’s secondary market conference sponsored by the Mortgage Bankers Association, Kevin Palmer, a Freddie vice president, said the government-sponsored enterprises launched their credit-risk transfers to reduce taxpayer exposure and distribute risk more broadly in the mortgage finance system. Fannie and Freddie have...
Morningstar Credit Ratings may increase its presence in the residential MBS market after rating its first re-securitization last week and revising its rating criteria for new non-agency MBS. The push follows Morningstar’s initial effort to rate non-agency MBS in 2012, which didn’t generate any business. The company has rated commercial MBS and single-family rental securities. Last week, the rating service published...