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Inside the CFPB
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Short Takes: Does the CFPB Understand the Mortgage Business? / Why Skyline Likes Wholesale / Nice GSE Bill, Guys. Too Bad It’s DoA / Mortgage Master Joins FTHB Compact / Relax, the MI Industry Will Be Just Fine?

July 14, 2014
Paul Muolo, Sherry Muolo, and Charles Wisniowski
Mortgage brokers who read the guidance said it reveals how little the young regulatory agency understands about the industry. If a broker has the financial ability to obtain a warehouse line of credit...
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Redwood Includes Non-QMs in Its Latest Jumbo Deal, Does Less than 100 Percent Due Diligence

July 11, 2014
Redwood Trust took three months off from issuing jumbo MBS but came back with something of a doozy this week: a $306.05 million deal that will include some loans that don’t meet standards for qualified mortgages and some loans that weren’t subject to third-party due diligence reviews. Sequoia Mortgage Trust 2014-2 is set to receive AAA ratings with credit enhancement of 7.75 percent on the top-rated tranche. While the credit enhancement requirements are somewhat high, a jumbo MBS from Redwood in November had even higher credit enhancement levels, suggesting that the non-QMs and lack of full due diligence aren’t a major concern. Only three of the 438 mortgages to be included in the deal are...
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New GSE Mortgage Insurance ‘Stand-In’ Does Nothing to Reduce Buyback Uncertainty

July 11, 2014
Charles Wisniowski
New GSE repurchase requirements are now in effect, including the “MI stand-in” option, which Fannie defines as “the full mortgage insurance benefit that would have been payable under the original mortgage insurance policy if the mortgage loan liquidates.”
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FHFA’s New HARP Effort a Waste of Time?

July 11, 2014
Charles Wisniowski
“We’ve got approximately $72 million [of HARP refinance business that can be done] in this metropolitan area," said FHFA director Mel Watt about Chicago. "People won’t come in and say I want that money.”
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‘Flood of Litigation’ Expected Against Non-Agency MBS Trustees for Failing to Pursue Buyback Claims

July 11, 2014
The six lawsuits filed in June by institutional investors against non-agency MBS trustees are just the beginning of actions against trustees, according to an attorney who has pursued representation-and-warranty claims against non-agency MBS issuers. “We are likely to see a flood of litigation against trustees alleging that the banks sat on their hands and blew the statute of limitations on valuable putback claims,” according to Isaac Gradman, an attorney at Perry Johnson Anderson Miller & Moskowitz. The June lawsuits by BlackRock, PIMCO and other institutional investors targeted...
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Fed Issues Action Plans for Goldman Sachs, Morgan Stanley to Improve Oversight of Third-Party Servicers

July 11, 2014
The Federal Reserve has released action plans for Goldman Sachs and Morgan Stanley to correct deficiencies in the firms’ risk management procedures for third-party mortgage servicers. The plans were a requirement under enforcement actions issued by the Fed and the Office of the Comptroller of the Currency between April 2011 and April 2012 against 16 mortgage servicers, including Goldman Sachs and Morgan Stanley. The servicers came under scrutiny for deficient servicing practices and foreclosure procedures, and later settled with the government. Morgan Stanley’s regulatory action plan supplements...
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MBS Investing REITs Have Been Paying Hefty Dividends the Past Few Years, But How Long Can the Gravy Train Last?

July 11, 2014
Real estate investment trusts that have been gobbling up MBS the past few years – and paying hefty dividends in the process – may have some more room to run, especially if interest rates remain relatively benign. “Given the tailwinds of lower prepayment speeds and Fed purchases, we believe that payout levels should remain stable in the near term,” said one veteran analyst who works for a top five bank. This analyst, who tracks several large REITs that invest in agency securities, added...
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SIFMA Urges Agencies to Band Together to Develop Common Diversity Rules for Financial Institutions

July 11, 2014
The Securities Industry and Financial Markets Association has called upon federal financial institutions and consumer protection regulators to form an interagency working group to establish joint, uniform diversity standards for the financial services industry. The standards would implement a requirement of the Dodd-Frank Act for consistent, uniform rules to assess the diversity policies and practices of financial institutions. The rules would also spell out criteria and procedures for determining whether a contractor or subcontractor has made a “good-faith effort” to include minorities and women in its workforce. Several of the agencies jointly proposed...
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Fitch Consolidates Key MBS Ratings Criteria in Master Criteria, Tweaks Grading, Tiering Systems

July 11, 2014
Fitch Ratings has consolidated a number of key rating drivers into updated master rating criteria for residential MBS backed by newly originated and seasoned residential mortgages. The latest report replaces the July 2013 RMBS criteria, and while no material changes have been made to the overarching process, a few tweaks have been made. The important rating drivers that were incorporated include...
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What We’re Hearing: Is Our Mortgage Origination Estimate Crazy? / Good News from At Least One Warehouse Lender / Bullish on Non-QM Lending? / The FHFA MI Proposal is Out and the World Hasn’t Ended, Yet / As for Radian… / Frank Raines’ New Job

July 11, 2014
Paul Muolo
So, you doubt our 2Q origination estimate? Here’s what an executive from a top-five warehouse bank told us: “We’re experiencing a significant pick up in outstandings."
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