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?
Compared to June 30, MBS investments by REITs are off 6 percent. Moreover, the industry has lost nearly all of the huge volume of MBS that were acquired in early 2012.
In our view, the primary risk associated with some lenders being less than fully prepared for QM could be temporary loan production delays, the consulting firm adds.