Wells Fargo Addresses "Illegal" Income; Forced Place Insurance Defined; Mortgage Jobs with a Twist;

In terms of foreclosures, California has been having a rough go of things recently.  The state has one of the highest rates of foreclosure in the country, but Keep Your Home California, which was established in 2010 and funded through the Hardest Hit Fund, aims to change that.  The initiative makes unemployed borrowers' payments for a period of several months, the idea being that this frees up time for them to find jobs and stabilize sources of income, and can provide troubled borrowers with as much as $100,000 under the Principal Reduction Program.  In order to be eligible, borrowers' income must fall underneath the income limit for their county (limits range from $69,500 to $123,600), and must have loans must be serviced by companies that have agreed to take part in the program.  With those eligibility requirements in mind, how effective has Keep Your Home California been?  Over its first year, about 10,000 homeowners participated, and the program's website has published a few success stories.  Considering that, at most recent count, California foreclosures numbered around 240,000, it's not a massive dent, but it's far from negligible.

Maybe Vikram Pandit ,who just stepped down this morning as Citigroup's CEO, and John Havens, president and COO, who also resigned, might be interested in these jobs:

With 66 years in the business Informative Research, an Orange County based company, is looking to add a national strategic accounts salesperson and a marketing/business development analyst. Informative Research helps mortgage lenders nationwide make sound risk decisions by offering a full suite of products covering Credit, Capacity, Collateral and Fraud. We are looking for people who have extensive contacts in the industry and who can make an immediate impact. The genuine team culture and underlying family company values make Informative Research a great place to work. Send your sales resume to the EVP of Sales, John LaBriola at johnl@informativeresearch .com  Send your marketing/business development resume to the VP, Business & Product Development Patrick Buckner at patrickb@informativeresearch .com  (Going to the MBA Conference in Chicago? So are they - feel free to set up a meeting.)

Here are underwriting jobs where you don't need to move or leave your regular job! "Give Your 203k DE Underwriters A Terrific Holiday Thank You! The holidays come early for 203k underwriting talent. Here's an unusual opportunity for any 203k underwriter who may want to fill their Christmas wallet with significant extra cash.  We need about 40 part-time 203k underwriters (with CHUMs number) to work on a special diligence project for 2-4 months. The job entails a very limited review of the value and LTV calculations.  A qualified 203k underwriter can perform this job in about 15 minutes per file and the job can be done on line. The underwriter needs to commit to doing at least 3 loans per hour and make some time commitment over the next few months. A qualified underwriter willing to put in a few hours over some evenings and the weekend can easily make $1-1500 extra per week. For managers, consider rewarding some of your best talent with extra money.  We can assure you this is a really unique opportunity and the personnel will not be shared with anyone else except this specialized vendor who will also provide an assurance of non-hire and non-solicitation. Send resumes or inquiries to 203kproject@thetomorrowgroup .com.

I don't know about you, but I've received about a dozen invitations to receive a FULL free registration to the NAMB National Conference, December 9-10. Las Vegas can be fun, but the industry is wondering about NAMB membership, expense problems, and trying to fill rooms...

If you think that you have a lot to do today, or over the next several weeks, think about the CFPB. They're going to revise TILA/RESPA ("know before you owe"), the ability to repay rule, HOEPA, LO compensation tuning, and the mortgage servicing rules. Granted, a fair amount of work has already been done, but the industry is especially waiting for Qualified Mortgage rules. But if the CFPB doesn't deluge the industry with new rules and regulations soon, statutory provisions kick in from Dodd Frank, Title XIV. And then later, when the rules are actually put in place, things will have to be changed again - and as we all know the markets rarely like change and don't like uncertainty. And when asked by Secondary Marketing about if the CFPB considers its impact on origination volumes and cutting off consumer credit, Richard Cordray subtly answered, "It's great for us to write a lot of protections for consumers on consumer credit,  but if they can't get credit, we haven't accomplished anything and we really haven't improved life for consumers." Tick tick tick...

Mortgage servicing comments ended last week, and the LO comp comment period ends today. You can comment, or read what others said, at http://www.consumerfinance.gov/notice-and-comment/.

What is forced-place insurance? The basic answer is, "Something you don't want to be involved in." "If you stop paying your insurance on your home and you have a mortgage on it, your lender will Google 'most expensive home insurance in the country' and purchase that for you. This is known as Forced-placed insurance. According to the NY Times the cost is 2-10x's as expensive as standard homeowner policies. Oh and guess what? The lender can receive a commission from a company affiliate too. There is pressure from the CFPB to have the lender advance money to keep the homeowners policy in effect rather than letting it lapse." So wrote Guy S. with CMG. Here's what the public sees.

"Rob, you mentioned Chase & Wells' results. Your readers might want to know about a story that CNBC ran titled, 'Can Little Banks Compete With the Big Guys?'.

Regarding trends in underwriting, Dennis Smith, co-owner of Stratis Financial, wrote, "I have seen many articles and commentary on how underwriting continues to get tighter and the primary---often sole---bit of evidence is the higher FICO scores for approved applicants. Of course the scores for approved applicants has climbed since most of the approved applicants are homeowners refinancing, in many (most) cases for the 2nd, 3rd, or 4th time since rates dropped. We have many customers who have been in their homes for many years, have had equity not entirely wiped out by the real estate crash and been able to refinance to lower and lower rates. Missing from the applicant pool, until recently, have been the first time buyers and prior-sub-prime borrowers who cannot refinance due to not having HARP eligible mortgages. Add to the mix the more stratified costs of mortgages based on credit scores which has caused many of us in the industry to encourage clients to spend a few weeks getting some debt paid down to raise their scores for a better rate. Yes the verification of funds has become more challenging (ridiculous in many instances as show in a few of your examples) but otherwise most of the guidelines are not much different than they were in the late 1980's and early 1990's; an era not a lot of current mortgage originators were around to experience. FICOs are higher for approved applicants, not because underwriting is tighter but because applicants as a whole have higher credit scores due to the vast majority being seasoned homeowners who have made their payments on time."

Speaking of underwriting, let's look at some relatively recent changes in investor, M&I, state, and vendor policies and procedures to give you a flavor for current events.

Radian released the delinquency data for September, and also spread the word that it wrote $3.5 billion of new mortgage insurance business and expects to maintain a risk-to-capital ratio below 25:1 in 2012. Good to hear! The delinquency data can be found on Radian's website.  Previously released historical data is also available on the website at http://www.radian.biz/page?name=FinancialReportsMortgageInsurance.

With a nod toward potential borrowers who earn money from medical marijuana, or practically anything else that would raise eyebrows, Wells Fargo's correspondent group announced, "Sellers are reminded that all income and asset sources used to qualify borrowers must be legal at the local, state, and federal level. Any income or assets derived from an activity or source that violates Federal, state, or local laws cannot be considered for Loan qualification in order to meet Wells Fargo Funding purchase requirements."

M&T Bank has updated its disaster policy for HARP 2.0 and FHA Streamline refinances such that re-inspection is required only up to four months after the disaster.  This replaces the previous requirement for inspection for the following 12 months. Following FEMA's announcement about disaster aid, M&T is requiring all properties in Baldwin, Mobile, and Pickens counties in Alabama to be re-inspected if their appraisals were completed before September 9, 2012.  The re-inspection must carried out by the original appraiser, include exterior photographs, and be completed using Freddie Form 442/Fannie Form 1004D to verify that the property has not been damaged.

As of October 1st, Stearns Lending will require that the loan originator's email address be disclosed on all GFEs.  Registrations that are currently in the pipeline and don't include this information will be accepted up until the end of September.

Following Freddie and Fannie's announcement about HARP changes, Genworth's mortgage insurance unit will be aligning its policies with the GSEs' HARP guidelines in an effort to make it easier for lenders to offer HARP refinances. 

The Cadent Group, a title, property tax, valuation, and analytics provider has announced plans to release the expanded version of its ValueXStream technology, which provides branded support for property tax initiatives for both large and small entities.  The updated ValueXStream technology has been designed to be integrated with loan origination systems and web-based applications; for more information, see www.thecadent.com.

In the wake of the severe storms in late July, FEMA has announced the availability of disaster aid for Ferry and Okanogan counties in Washington.

Illinois has amended the Illinois Lending Database provisions of the Residential Real Property Disclosure Act to include further requirements that will go into effect on January 1, 2013.  These requirements dictate that originators and title agents include certain data for mortgage applications in Cook, Kane, Peoria, and Will counties; title agents are also required to attach a Certificate of Compliance or a Certificate of Exemption to all mortgages.  The amendment also requires that additional income and expense information be included in each loan application.

There isn't much volatility to report on interest rates, which is fine by practically everyone on the origination and hedging side. Monday we learned that Retail Sales rose 1.1% in September, with some back-month revision higher. Given that economists point to how 70% of the U.S. GDP is made up of consumer spending, this is important. But investors still want to own our fixed income securities as a safe haven, despite the fiscal deficit and impending tax and spending measures that are set to expire in a couple of months. Besides, if our economy worsens due to our government's inability to act, that will lead to lower interest rates anyway, right? The 10-yr closed at a basically unchanged level of 1.67%.

Turning to mortgage pricing, Tradeweb reported that MBS volume at just 77% of its 30-day moving average. One item of interest, pointed out by Thomson Reuters, was a speech by New York Fed President Dudley "in which he commented on the widening in the spread between primary mortgage rates and secondary mortgage yields which has 'limited the drop in primary mortgage rates.' Several reasons for this are: lack of mortgage banker competition, rep & warranty concerns, and increased g-fee charges by the GSEs. These, in fact, were highlighted by Mr. Dudley who added 'Factors limiting pass-through warrant ongoing attention from policymakers.' Given the price levels on MBS, talk of changes that might help homeowners refinance tends to send a shudder through the market.

After a pretty quiet night this morning we've had the Consumer Price Index for September (+.6%, core +.1%, about as expected). We also have the duo of Industrial Production and Capacity Utilization (expected +.2% and 78.3%, respectively), and another housing health indicator (NAHB Housing Market Index). Although there isn't much going on, rates have crept a little higher, with the 10-yr at 1.70% and MBS pricing worse about .125.

Halloween approaches - a time of masks. A clever 30-second commercial (you'll need sound):
http://www.youtube.com/watch?v=Hy-rtCKBqWg.