After ending fiscal year 2012 at a negative $16.3 billion, the FHA’s mutual mortgage insurance fund is close to being in the black, according to an independent actuarial report released late last week. The FHA noted that it has shifted its focus from shoring up the MMIF to reducing lenders’ underwriting overlays and targeting poorly performing servicers. The net worth of the MMIF at the end of fiscal year 2013 was negative $1.3 billion, according to the report, due to pricing and policy changes by the Department of Housing and Urban Development along with improvements to the economy. The capital reserve ratio for the MMIF also improved from negative 1.44 percent at the end of fiscal 2012 to negative 0.11 percent at the end of fiscal 2013. HUD Secretary Shaun Donovan noted...
In just a few weeks, it will become clear whether the Consumer Financial Protection Bureau’s ability-to-repay rule will be the industry’s Y2K moment. But in the meantime, three top industry attorneys shared some final advice and guidance during a QM “double check” webinar sponsored by Inside Mortgage Finance last week. Joseph Reilly, a partner at BuckleySandler LLP, emphasized the critical importance of lenders documenting their compliance with the new regulation. “If a tree falls...
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?”
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