As part of the CFPB’s public forum last week during which the agency announced its forthcoming eClosing pilot project, the bureau also issued guidelines that articulate the minimum functionalities required of potential participants and spell out the features the CFPB wants to test in the pilot. To join the bureau’s pilot on electronic closings, each participant must currently have a system that meets minimal technical capabilities and requirements, as demonstrated by specific features and functionalities. “The CFPB created these minimum requirements to ensure that the pilot program is focused on the specific features and consumer outcomes that the bureau is seeking to evaluate,” the agency said.First, a pilot participant must have an eClosing solution with the ability to store...
One option that some affiliated business arrangements can use as a mechanism to cope with the CFPB’s ability to repay rule is to change their ownership structure, according to a top industry compliance attorney. Loretta Salzano, a founding partner of Franzén and Salzano, warned attendees at the recent Real Estate Settlement Providers Council’s 2014 annual conference that, “Lenders with affiliated providers must consider the ATR’s impact on their business based on the number and type of affiliates, the break point based on fees of all affiliates, the average loan amount, and the markets served.” Part of that process means lenders have to look and see where their break point is, the point at which they will breach the 3 percent...
The CFPB and the Federal Housing Finance Agency apparently are mailing $5 bills as “a small token of appreciation” to new homeowners to encourage them to participate in a survey associated with the agencies’ joint project to develop a national mortgage database, Inside the CFPB has learned. “I am writing to ask for your help with an important national survey of consumers about their mortgage loan experiences,” says a joint sample letter prepared with CFPB letterhead, with room for a signature for a representative from both agencies. “I understand that in the last 12 months you obtained a mortgage for your home (or a residence that is rented or otherwise occupied by others). Your recent experience is very important to...
A steep 46.8 percent plunge in consumer complaints about loan modifications in the first quarter from year-ago levels fueled a 29.3 percent drop in overall gripes to the Consumer Financial Protection Bureau from the same time last year, according to a new analysis by Inside the CFPB. Grievances about the loan application/mortgage origination process fell almost as much, down 26.7 percent, year over year. While mortgage-related complaints were down on a yearly basis, gripes regarding mortgages increased by 20.0 percent in the first quarter of 2014 compared with the previous quarter. Another key quarterly performance metric, grievances about servicing, trended up as well, increasing by 29.1 percent versus the period ending Dec. 31, 2013. [Includes two exclusive charts]...
Who gave up market share to nonbank lenders? The biggest decline was among banks with over $1 trillion in assets: JPMorgan Chase, Wells Fargo, Bank of America and Citigroup.
Commercial mortgage securitization – including non-agency commercial MBS and multifamily securitizations by Fannie Mae, Freddie Mac and Ginnie Mae – declined by 22.1 percent in the first quarter of 2014.
A total of $32.6 billion of income-property mortgages were securitized during the first three months of 2014, a soft beginning for a market that posted its best year since the financial collapse during 2013. Commercial mortgage securitization – including non-agency commercial MBS and multifamily securitizations by Fannie Mae, Freddie Mac and Ginnie Mae – declined by 22.1 percent in the first quarter of 2014. Total issuance was off 30.4 percent from the same period last year. Both agency and non-agency issuance was...[Includes two data charts]
Servicer-advance rates on vintage non-agency MBS have been up and down in recent quarters, showing further variances based on the servicer and issuer. The fluctuations have made it difficult to project valuations for certain securities, but industry analysts suggest that as mortgage performance continues to improve, servicer-advance rates will stabilize. The rate at which servicers advanced missed borrower payments on mortgages in non-agency MBS decreased slightly on a quarterly basis in the first quarter of 2014 after a gain the previous quarter, according to Fitch Ratings. Pooling and servicing agreements for non-agency MBS require servicers to continue making advance payments until the payments are deemed non-recoverable. Non-agency MBS values are...