Due-diligence and document-file reviews will key Fitch’s rating of residential MBS backed by re-performing loans and seasoned mortgage loan collateral, based on revised criteria, according to a recent report from Fitch Ratings. Fitch recently finalized its criteria for analyzing re-performing and seasoned loan RMBS to include closer attention to risk factors. Fitch uses its mortgage loan-loss model as well as representation-and-warranty and due-diligence reviews in analyzing the key risk drivers for RPLs. However, since the methodologies currently used by the rating agency were developed with an eye towards newly originated and seasoned performing collateral, RPL pools and some seasoned performing pools purchased in the secondary market are likely to be influenced...
Ocwen Financial, which has been under intense regulatory scrutiny most of the year, stopped buying delinquent loans out of Ginnie Mae pools during the third quarter, according to a review of loan-level data by Inside MBS & ABS. The cessation of buyouts is unusual and has some MBS analysts scratching their heads, wondering whether more trouble could be afoot at the nation’s largest nonbank servicer. According to a new report from Barclays, the reduction in buyouts by Ocwen (as measured by prepayments) “could be due...[Includes one data chart]
The Federal Housing Finance Agency is continuing to work on new standards that will dictate not only how much capital nonbank servicers must retain, but how much in liquidity reserves they will need, according to industry analysts and advisors familiar with the topic. Moreover, these officials believe that some type of unveiling of those standards – originally planned for December – has been pushed into the first quarter of 2015. “One problem [the] FHFA is facing is...
The multi-agency final rule implementing the Dodd-Frank Act appraisal-related amendments to the Financial Institutions Reform, Recovery, and Enforcement Act is expected sometime this month, according to the Consumer Financial Protection Bureau’s semi-annual regulatory agenda. The amendments made by Dodd-Frank to FIRREA require new minimum requirements to be applied by states in the registration, reporting and supervision of appraisal management companies (AMCs). They further require implementing regulations for new quality control standards for automated valuation models (AVMs) “designed to ensure a high level of confidence in the estimates produced by the valuation models.” The pending regulations also are...
State-regulated lenders and servicers will be required to report new information on servicing and originations to regulators beginning in the first quarter of 2015. Lenders weren’t able to win many concessions from the Conference of State Bank Supervisors, which proposed reporting changes for the Nationwide Mortgage Licensing System & Registry’s Mortgage Call Reports in October. The State Regulatory Registry, a subsidiary of the CSBS that operates the NMLS on behalf of state regulators, positioned the reporting requirements as part of an effort to reduce regulatory burden for lenders. “A goal of the MCR is...
This week, the U.S. Supreme Court heard oral arguments in two consolidated cases on whether the overtime provisions in the Fair Labor Standards Act apply to mortgage loan officers – and the narrower question of whether federal agencies have the authority to make regulatory changes without using the “notice and comment” rulemaking process. Both cases involve the Mortgage Bankers Association as the respondent. The U.S. Department of Labor argued...
The MBA’s legal counsel tried to begin by focusing on the dividing line between interpretative rules and legislative rules, but soon found herself having to defend the trade group’s support for the DOL’s original 2006 position.