Several commenters argued that any capital requirement on commingled securities might interfere with the fungibility of the uniform mortgage-backed security.
HUD's IG questioned whether Ginnie could relocate a troubled MBS portfolio from one issuer to another if the first is facing financial or operational challenges.
Companies’ boards and senior management need to “recognize the inherent risk of the HMDA process” and provide human and capital resources to it, according to the Fed.
It was originally thought that publicity generated by the consent order would cause at least some of Cenlar’s subservicing clients to switch vendors. But so far, that hasn’t happened.