New LO Referral Service; HARP Expansion Update; MBA Comp Survey; Possible HMDA Change Info
"Any idea how much Realtors make?" I don't know, and asking someone their income isn't always the wisest of moves, especially on a first date. But the NAR takes the guesswork out of it by publishing median (half above, half below) incomes, ages, and so on, of its members in its Membership Profile.
And in this year of industry transition here is an interesting approach: a service that helps one find reputable, vetted LOs outside of your area. "Have you ever had a request for mortgage financing outside your licensed area and wanted to be sure they got the best service (without losing your customer)? Good news: now you can easily and confidently make referrals anywhere in the country! Premier Mortgage Network, LLC sought out elite mortgage professionals with a reputation for world class customer service and thoroughly vetted them to ensure they are the best of the best. Confidently send your referrals to an outstanding mortgage professional that will provide the same exceptional service you do (you'll even get updates)! to register and gain access to this network. There is never any cost to you or your clients to use this service. If you have any questions, please contact Julie Diamond at jdiamond@pmnhq.com."
The MBA also continues to gather information, and came out with its latest compensation benchmarking study. "MBA's benchmarking studies offer mortgage companies better business intelligence when making important personnel and operational changes to adapt to this regulatory climate. For ten years, MBA has recommended the annual Residential Mortgage Banking Compensation Survey Program to its members as they develop and implement their individual compensation strategies. This year's program includes the 2014 Residential Compensation Survey that profiles more than two hundred positions across all mortgage-related lines of business and functional areas. Among the elements covered: base salary, cash bonus, total cash, commissions, overtime, total compensation and long-term/deferred awards. Reports include scoping factors such as geographic region, number of employees, revenue size and total loan volume. In addition, productivity data is collected and included in the report at the individual level (i.e. loan officer loan production); three specialized compensation benchmark products that are focused on production, servicing and corporate/executive functions; a 1½ day MBA Human Resources Roundtable in September. Open to participants in the survey, this interactive workshop offers a unique opportunity for attendees to network with peers, while analyzing the latest in compensation benchmarking data and human resource trends. Results from the 2014 Residential Compensation Survey will be presented. Registration and participation in the program is required in order to receive the results and MBA members receive a significant discount off the regular survey pricing. The survey questionnaires will be sent in March. Publication of the survey is anticipated for August 2014. Please complete the registration form today to secure your firm's participation in this program, or if you have general questions, please contact Marina Walsh, MBA Research, at MWalsh@mba.org.
The MBA is definitely following the HMDA developments. But what do credit unions think of the CFPB's quest for more HMDA information? Here you go.
The MBA sent out an update saying, "The CFPB began the process of revising the Home Mortgage Disclosure Act (HMDA) rules to require lenders to collect and report several new data elements. Some of these new data elements are specifically required under Dodd-Frank. However, the Bureau is also considering requiring some additional data elements. The CFPB is also considering changes to the collection rules to streamline reporting and improve data entry. Finally, it is also considering revising the reporting thresholds so all banks and non-banks report if they make 25 or more mortgage loans in a year. A summary of the data elements sought by the CFPB is here. Notably, Dodd-Frank adds the following HMDA data elements (unless the CFPB decides otherwise): total points and fees, and rate spreads for all loans (not just HPMLs); risky loan features including teaser rates, prepayment penalties, and non-amortizing features; the length of the loan; expanded lender information, including a unique identifier for the loan officer and the loan; property value and improved property location information; borrower age and credit score.
The CFPB is also considering requiring: mandatory reporting of reasons for denial; debt-to-income (DTI) ratio; Qualified Mortgage status of loan; combined loan-to-value (CLTV) ratio; automatic underwriting systems results; additional points and fees information (including interest rate - HMDA requires APR currently, total origination charges, Bona Fide and Total discount points, risk-adjusted, pre-discounted interest rate); whether loan has affordable housing deed restrictions; and manufactured housing data.
"As a first step in revising the rules, the CFPB has convened a small business review panel required under the Small Business Regulatory Enforcement Fairness Act (SBREFA) to provide input on the changes under consideration, focusing particularly on the burden these requirements would create. Over the next few weeks, the CFPB will conduct several conference calls with the SBREFA panel and an in-person meeting in Washington DC in early to mid-March. Following the conclusion of the panel's work, the CFPB is expected to issue a proposed rule. At least four members of the panel are employees of MBA member companies and MBA is acting as a resource to industry panelists. MBA believes that the new data collection requirements present several important concerns that must be resolved to avoid undue operational burdens and litigation risks-especially in light of HUD's recent disparate impact rule. MBA also wants to ensure that consumer privacy is not compromised under any new HMDA regime. MBA will raise these and other issues in the rulemaking process. We are at the beginning of what should be a lengthy process. Any new HMDA rules are unlikely to require new data until 2016 at the earliest. We will provide updates as this important process moves forward."
"Rob, what do you hear about the government expanding HARP? If they do, will we see another refi boom?" I hate to be the bearer of bad news, but a story in Bloomberg last week filled us in. "HUD's Donovan Confirms HARP Won't Be Expanded, FBR Says." "Now HUD has joined the Treasury on doing nothing with regard to HARP, which makes it a bit more difficult for Watt to garner support for material changes." "HUD Secretary Shaun Donovan made it clear yesterday at a Politico event that his department. Will not push for HARP expansion, confirms that no broadening of program should be expected, FBR analyst Ed Mills writes in a research note. Donovan believes improving access to credit for mortgage borrowers remains HUD's most important policy challenge. Sees Wells Fargo's pursuit of 600-640 FICO FHA borrowers as positive sign for credit availability. Donovan is cautiously optimistic about FHA's finances; following last year's infusion of taxpayer money into FHA, many in Washington concerned about its balance sheet."
Turning to some recent lender, investor, and vendor news...
Green Tree is prohibiting the use of a Power of Attorney to execute documents for cash-out refinances and Texas 50(a)(6) transactions. In addition, lenders, affiliates of lenders, any employee of lenders or their affiliates, loan originators, loan originators' employees, title insurance companies, and real estate agents with a financial interest in the transaction may not sign the security instrument or note as the attorney-in-fact or agent under a Power of Attorney.
Green Tree has revised its guidelines to specify that leasehold agreements pertaining to purchase transactions must not have any servicing reporting requirement to the lessor, and the lender must not be required to sign a subordination document. For permanent financing on new construction, guidelines have been updated to require that the LTV/CLTV be based on the appraisal, both in lot and improvements, regardless of how long the borrower has held title to the lot. The same calculation applies to cash-out refinances; in addition, borrowers must have held title to the lot for at least six months prior to the closing of the permanent mortgage.
Per Green Tree's updated underwriting guidelines, borrowers must have a credit history sufficient to make a determination of creditworthiness and a minimum of three open tradelines, each of which should be rated and paid within the past 24 months. In cases where the borrower has revolving debt that they wish to pay off for loan qualification, the account must be paid in full and closed at or prior to closing. The creditor should certify that the account is closed with no outstanding transactions, and the borrower's source of funds must be documented.
Green Tree has revised its employment verification policy to require the borrower's most recent account statement if the AUS returns an Approve status and either a Verification of Deposit or the two most recent consecutive monthly account statements in the case of a Refer status or manual underwrite. FICO guidelines have been relaxed, and instead of a minimum of two reported credit scores, underwriters may use only one score if it is reported and accepted by the AUS.
Effective immediately for all Jumbo transactions, Green Tree is considering borrowers who are re-entering the workforce to have stable employment if they have been employed in their current job for six months or more and if the loan file includes documentation of a two-year work history prior to the absence.
Homeward has revised its Conventional guidelines on condo/PUD flood insurance; derogatory credit; and minimum borrower contributions when gift funds are being used to align with those of the Agencies. For the FHA 203(b) loan program, the policy on gaps in employment has been updated to align with FHA guidelines.
First Community Mortgage has launched its new Lender Paid Mortgage Insurance program, which offers both Conforming and high balance loans with LTVs over 80%, and has expanded its LP Relief Refinance program to allow LTVs from 105% to 125%.
Radian Guaranty has released its December delinquency data, reporting $2.85bn in new insurance and primary delinquent inventory as dropping from 62,556 loans to 60,909 loans. There were 4,650 new delinquencies, which were offset by 4,104 cures, 2,084 paids, and 109 rescissions and denials.
As noted yesterday, there is a decent line-up of economic news coming our way this week. Inflation has not been an issue for many, many years, but still analysts talk about it - especially when there isn't much else to talk about. We'll have the monthly inflation reports: the Producer Price Index (PPI) and its sibling the Consumer Price Index (CPI) out Wednesday and Thursday, respectively. The minutes from the January 29 Federal Open Market Committee Meeting will be released on Wednesday, as will Housing Starts. Its cousin Existing Home Sales will be released on Friday. Throw in today's Empire Manufacturing, the Philly Fed, NAHB Housing Market Index, Leading Economic Indicators, and Jobless Claims, chocolate chips, mix well, and put in the oven at 375 for 12-15 minutes.
The yield on the 10-yr Friday closed at 2.75%, which is where it spent much of the week. In the very early going today we're at 2.73% and agency MBS prices are a shade better.
It is imperative, through this 41 second video, to stay up on the latest Olympic sports. I don't think you'll be sorry.