Wells, Bank of America and JPMorgan Chase accounted for a combined 44.7 percent of the $517.75 billion in bank HELOCs outstanding at the end of the third quarter.

Advisors note that Walter should be concerned that it has a large MSR portfolio – $194 billion at Sept. 30, according to figures compiled by Inside Mortgage Finance – but a relatively small origination platform.

“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.

CashCall, once a top ranked refi specialist, is owned by mortgage industry veteran Paul Reddam.

Loan broker Anne James, who runs Reliance Funding in Wittier, CA, told us recently that “I have wholesale lenders calling me daily to sign up.” She notes, however that “Loans are not dropping out of the sky” but adds that she’s getting quite a few calls for second mortgages.

Among other things, the FHFA wants to know if six-months is adequate time for lenders and servicers to make the changes to their technology systems.

During the first half of 2013, only about $2.05 billion of FHA loans exceeded $625,500, or about 1.5 percent of FHA business, according to Inside Mortgage Finance.

Lenders generated an estimated $218 billion in purchase mortgages during the third quarter, the highest three-month volume since the third quarter of 2007.

“There has been significant industry confusion concerning the extent to which affiliate fees are included in the points-and-fees calculation, particularly when only a portion of a fee is retained by an affiliate,” the Mortgage Bankers Association said.

According to an analysis by Inside Nonconforming Markets, Fannie Mae’s portfolio of guaranteed subprime mortgages is declining much more rapidly than Freddie’s.