AIG Eyes Residential Lending; Big Banks have 2nd Chance at Passing Stress Tests

By: Rob Chrisman

Well, you gotta hand it to those independent-minded folks over in Texas, who once again are asking to secede from the Union. Let's see what that does to its state-specific gfee and loan level price adjustments!

A Missouri-based wholesale mortgage banker, Equitable Mortgage Corporation, is continuing its expansion into Arkansas and Kansas and is looking for AE's. With 16 years of experience they offer turn-key secondary market access for community banks, provide in-house underwriting, and boast programs for Large Acreage, Rural Properties, Conforming, FHA, VA, and USDA,.  Account Executives currently living in these markets that are interested in developing Community Bank partnerships are encouraged to submit their resume to Wholesale Lending Director, John Cardoza, john@equitablemortgages .com. Previous retail or wholesale residential lending experience is required - learn more about the company at equitablemortgages .com.

As the CEO of an independent mortgage banking company, are you concerned about the financial, competitive and compliance viability of your business model over the coming cycle?  You may be interested in exploring an opportunity to be acquired by a federally-charted (FDIC) community bank that was founded in the mid-1800's. I have been retained to identify a retail production entity with a strong purchase orientation that is originating from $20 million to $100 million monthly.  There are no geographic restrictions, and my client brings a solid mortgage banking culture which has evolved over 30 years and which will close $2.5 billion in 2012 in all 50 states.  The acquired company would enjoy numerous tangible benefits: Fannie/Freddie approvals, significant warehouse spread, proven and tested compliance practice, scalable state-of-the-art Information Technology platform and a solid back office which delivers consistently competitive service levels (like consistent 72 hour underwriting turn times).  I welcome your inquiry to discuss this opportunity in strict confidence: rchrisman@robchrisman .com.

"The road to success is under construction." And it appears that AIG, the owner of UG, is under construction and gearing up to possibly become a direct lender. Anyone wanting to sell their operation to it, step right up! Seriously, here is the article, complete with exotic locales right out of a James Bond movie.

Remember how, in some classes, the teachers might let you drop your worst test? "The Federal Reserve will give the 19 largest banks a preliminary result of its capital stress test, offering institutions that fail a chance to adjust their dividend and stock buyback policies. The change comes after Citigroup and SunTrust narrowly missed meeting the 5% tier one common equity to risk-weighted assets minimum capital ratio in the 2012 test at 4.9% and 4.8% respectively. Ally Financial had a stressed ratio of 2.5 percent in the last test".  More

"I've been reading with interest the issues regarding fair lending, steering, redlining and disparate impact in you daily newsletter.  My discussion group on linked in addresses those issues every day.  If your readers are an Optimal Blue user they can join the group at "Optimal Blue Fair Lending and Compliance Group". If they are not, the can access the same articles on our external blog which is optimalbluefairlending .com." Thank you to Tammy Butler, the Director Fair Lending and Compliance with Optimal Blue.

Speaking of lending in a compliance-heavy environment, the Bank of America Mortgage lawsuit (Countrywide "Hustle" scheme) offers other lenders examples of a thing or two to learn. Remember that prosecutors are suing for $1 billion over Countrywide's "Hustle" scheme, which facilitated the sale of thousands of fraudulent and otherwise defective loans to Fannie and Freddie. The filings contend that Countrywide "eliminated every single checkpoint on loan quality and compensated its employees solely based on the volume of loans originated" into 2009, well after it had been acquired by BofA.  With the allegations of employing unqualified underwriters, concealing quality control reports that disclosed astronomical defect rates, and even using Wite-Out, scissors, and tape to alter documents, it's safe to say that the suit is unlikely to garner BofA and the late Countrywide any sympathy from the general public. Of course at this point our government has brought suit against it, JPMorgan Chase, and Wells Fargo (the last two by the New York AG and the Department of Justice, respectively).

The NAIHP has a new petition circulating, this one about appraiser independence: http://www.naihp.org/.

On to some other somewhat recent agency, investor, and MI updates, along with the usual disclaimer that it is best to read the bulletin for full details, but this will give you a flavor for current trends.

Wells Fargo has aligned its income qualification and documentation requirements for manually underwritten conventional loans with those outlined by Fannie. This affects Wells guidance on documentation of commissions, bonuses, overtime income, alimony, child support, separate maintenance, royalties, and trust income.  The income continuance policy for non-conforming loans has been updated as well.  For income types with set durations (alimony, relocation compensation, child support, etc.), Wells previously required a minimum of three years' guaranteed continuance, but this has been changed to five years.  In cases where the income source makes up less than 25% of a borrower's total qualifying income, the three year requirement remains.

Wells will be updating the Loan Submission Summary, the revisions to which will affect all closed loans that are received on January 2, 2013 and after.  The changes affect the disclosure of the Final Borrower Rate Lock Date, conventional New Construction loans, and borrowers' tax information, including borrowers who are exempt from property taxes, borrowers who elect not to create a monthly tax escrow, and the Economic Loss Date in cases where there are multiple taxing authorities.

Sellers originating Guaranteed Rural Housing loans are reminded that they are required to comply with USDA RD Office, Agency conventional loan program, GRH, and Wells' own GRH policies, particularly with regards to repair costs, as this has apparently become an issue.  Neither Wells nor RD limits the amount of repairs that may be financed, but repairs aren't permitted to be financed unless the property's post-repairs appraised value supports the loan amount. 

Citi reported an increase in the number of purchased loans with credit reports that contain security alerts, which are used to notify consumers that their identity may have been stolen and used to purchase goods or services.  Lenders are reminded that Citi will not consider such loans eligible for purchase until it has received verification of the borrower's identity, the details of which should be provided by the reporting agency.

Fifth Third requires that loan officers sign and date the initial 1003 at the time of initial applications.  At present, electronic signatures and/or delivery aren't permitted for any loans delivered to Fifth Third. A free 15-day lock extension will be applied to all active Fifth Third loans in federally declared disaster areas in cases where the current lock expiration date is in the month of November.

Flagstar published the list of counties and zip codes in Connecticut, Delaware, Massachusetts, Maryland, New Jersey, New York, North Carolina, Rhode Island, and Virginia where it will be requiring appraisal re-inspections for all properties whose appraisals are dated October 31st or before.  Clients should note that the re-appraisal requirements for FHA loans have been revised to state that loans that don't disburse within the month of payment being due must be re-underwritten.  In addition to the re-inspection, loans must be accompanied by an updated payoff letter, updated Refinance Authorization, updated asset verification, proof that the case number hasn't expired, and evidence that the borrower made all mortgage payments apart from the one due for the month the loan will disburse.

Lenders are no longer required to submit copies of the prior note for Flagstar-underwritten FHA Streamline refinances or FHA Streamline refinances underwritten by DE Delegated correspondents.  Flagstar now uses title commitments, payoff statements, credit reports, and FHA Refinance Authorizations to determine the FHA's net tangible benefit requirement.

Until further notice, US Bank has postponed its scheduled appraisal ordering fee increases, which were originally meant to go into effect on November 4th.

Provident Funding will be making adjustments to appraisal fees in various markets that will go into effect on December 1st.  See the appraisal pricing table for full details (http://news.provident.com/DownloadAttachment.aspx?id=170).  Changes have also been made to the complex assignment and fee disclosure sections of the appraisal order form, and the Provident website will allow users to upload building permit documentations for any alterations made to the property in order to explain discrepancies with public records.

GMAC's appraisal fees have also been updated; see the matrix for the full changes.

Kinecta has revised its documentation guidelines for refinances in community property states where a spouse or registered domestic partner wants to maintain the property as his or her sole and separate property.  Under these circumstances, Kinecta now requires evidence of a newly recorded document to ensure clear title, the specifics of which will be dictated by the title company.

Mountain West Financial has removed the 45% DTI maximum it had previously imposed on Fannie High Balance and Freddie Super Conforming loans.  Ratios will be accepted as determined by DU or LP.

Rates are good - enough said?! They're even better this morning than where they were Friday. Markets don't like uncertainty, so with the election out of the way, and Congress back to work in its lame-duck session, that will dominate the press (Petraeus scandal aside: "In the Line of Booty"). Everyone says they want a deal, but actually doing it prior to December 31 remains to be seen. Last Tuesday's results also increased the chance that Fed Chairman Ben Bernanke will finish out his term, set to end in Jan. 2014, and not be replaced with a more hawkish chairman.

So every LO should be excited, since this suggests that monetary policy will stay on its extremely accommodative course, even if the economy strengthens at a faster pace than currently anticipated. And in fact the economy looks decent - or at least the recent standard of "sluggish growth." The ISM non-manufacturing index showed that the service sector continues to expand at a moderate rate. The international trade report for September came in better than expected. For the labor market, jobless claims looked slightly better on the surface, but are being distorted by the early effects of Hurricane Sandy.

As mentioned, rates are better today than on Friday. The U.S. 10-yr is down to 1.60% (after being in the high 1.50's overnight) and agency MBS prices are better by about .125-.250 depending on coupon. There really is not a lot of market-moving news for a couple days - more on that later in the week.

We'll take a break from the usual joke to give some travel advice, especially as we're coming up on the holiday season. A new survey by flight search engine Kayak.com says the lowest domestic flights can be found 21 days before your date of departure-make that 34 days before your departure date for international flights. Domestic airfares found within two weeks of departure increased by five percent, and were 30 percent higher one week before the departure date. The international airfares found 34 days prior to departure were four percent lower than flights booked six months earlier than the departure date. The new findings come from compiling and analyzing one year's worth of search results data from an average of 100 million flight searches per month. Here's something counterintuitive; The results suggest that you should NOT book domestic flights too early, as those reserved six months before the departure date were 19 percent higher, and flights found five months ahead were 18 percent higher than flights booked 21 days before departure.

Which days of the week you fly also make a difference. When booking domestic flights that are up to one week long, Kayak found that the lowest-priced fares depart on Saturday and return on Wednesday, while flights longer than one week that depart on Tuesday and return on the following Wednesday have the lowest-priced fares. For international flights up to one week long, Kayak recommends departing on Tuesday and returning on the following Wednesday, or departing on either Friday or Saturday and returning the following Monday-for trips longer than one week, try departing on Saturday and returning the following Sunday, or aim for the second-cheapest set of airfares by returning on Monday, Tuesday, or Wednesday. Read more.