More than any time since before the Great Financial Crisis, the disconnect between Washington policy makers and the actual reality in the mortgage markets is widening. The lack of real-world knowledge and comprehension by key agency heads in the Biden Administration begs the question whether Washington is a help or a hindrance as the industry grapples with rising interest rates and mounting credit loss expenses.
For example, Consumer Financial Protection Bureau head Rohit Chopra said in May that "a major disruption or failure of a large mortgage servicer really gives me a nightmare." He made these intemperate comments during
Like his predecessor Richard Cordray, Chopra's focus is political rather than on any real threat. But of course, progressive solutions require problems. Three large and mismanaged depositories
The big risk posed by mortgage servicers, of course, is to shareholders and creditors, not to consumers. Witness the abortive auction for Specialized Loan Servicing by Computershare of Australia. The offering of private label servicer
When progressive politicians in Washington yowl about risk in the financial markets, it is usually really about risk to the personalities in question and financing their careers. There is no appreciable risk to consumers or the taxpayer from mortgage servicers, which like Black Rock and UBS are basically asset managers working for a fee. Bureaucrats like Chopra simply raise operating costs.
More than any real world problem posed by IMBs, it is the government in all of its manifestations that poses a significant risk to the world of mortgage finance and the housing sector more generally. Washington regulatory agencies seek to stifle the markets, limit liquidity and impose additional capital rules, strictures that must inevitably reduce economic growth and access to affordable housing.
The good news, of course, is that many of the proposals from the FHFA, HUD and other agencies are effectively modified or
In this case, Washington listened, but only after taking an inordinate amount of time and resources from private issuers, resources that are badly needed elsewhere. Would it be too much to ask for government agencies to vet ideas thoroughly before a public proposal?
In other cases, however, as with the risk based capital rules proposed by Ginnie Mae and the capital rules already approved for the GSEs, Washington is definitely not listening. But then again, the industry did a lousy job of pushing back on the capital rules for Fannie Mae and Freddie Mac, to our great disadvantage.
Despite the withdrawal of the LLPAs, personnel at the GSEs are still pressing issuers for "mission loans," meaning loans to underserved and generally low-quality borrowers that are sought by the Biden Administration. Some issuers approaching the GSE cash windows have been told that they will not receive attractive pricing unless the pools include mission loans.
But sadly, there are few cases where a lender could or should advise a consumer to take out a conventional loan vs. FHA/VA. And the execution from the GSEs is hardly attractive.
The changes in GSE loan pricing and other policy changes reflect the FHFA's focus on implementing the enterprise capital requirements put into place by Thompson, even while paying lip service to progressive goals. Garrett Hartzog, Principal of FundamentalAdvisory and Consulting
"The Enterprise Regulatory Capital Framework is going to dramatically transform GSE pricing in ways the industry hasn't begun to contemplate. Understanding the ERCF means being able to mentally reconcile increasing risk-based pricing (the DTI-based fee) and decreasing the level of risk-based pricing (the credit score/LTV matrices). What's more, people need only read Fannie Mae and Freddie Mac's comment letters during the rulemaking process to understand that g-fees will ultimately experience a dramatic increase as a result of the ERCF."
If FHFA raises guarantee fees for the GSEs in line with the capital rule, then Fannie Mae and Freddie Mac will no longer be competitive for larger, high-FICO loans. But poor execution at the cash window and higher g-fees are just some of the issues facing the GSEs as defaults rise and loan put backs also increase.
A number of issuers complain about an
Meanwhile, the FHFA has just rolled out a new program whereby all large conventional issuers
One angry issuer tells NMN: "If your volume is mostly FHA/VA, it does not matter to the FHFA. They want QC on all loans. If my volume is mostly delegated correspondent, it does not matter. I'm buying closed loans, but it does not matter."
Most issuers contacted by NMN say they cannot comply with the new QC edict from FHFA. The lack of appreciation for market realities within the FHFA mirrors the situation in much of official Washington, with regulators working against the best interests of consumers and the entire private mortgage and housing industry by reducing volumes and liquidity.
Ironically, even as the FHFA is becoming the focus of increased industry concerns, Ginnie Mae President Alanna McCargo is now focused on problems faced by issuers. The new partial claim regime put in place by the FHA to help finance loss mitigation for Ginnie Mae servicers evidences this concern.
The CEO of one lender that focuses on underserved communities told NMN: "Ginnie Mae understands that they need to let us run our businesses as delinquency rates rise. Until interest rates fall and volumes improve, this is a war of attrition among lenders."
Lenders hoping for lower rates in 2023 and that are dragging their feet on cost cutting will not survive in many cases. With the markets extending spreads on late vintage production, the MBS with 6% and 7% coupons, higher for longer seems to be the plan in residential mortgages in 2023. Hope is not a strategy.
