Caliber is worried that if interest rates rise from current levels, the volume of prepayments and mortgage payoffs is likely to decline, which will reduce the cash available to fund servicing-advance obligations.
The rescission of the bulletin does not mean MSAs are presumably legal. Instead, it will depend on how the business relationship is structured and implemented.
More importantly, the analyst noted, the council threatened to impose still stricter standards or designate the GSEs as systemically important financial institutions if the capital rule was materially softened.
This official speculated that perhaps Calabria was referring to the companies’ corporate culture before the financial crisis, when the politically connected secondary market giants were widely feared on Capitol Hill.
Tom Piercy of IMA: “Any type of additional regulatory discussion is problematic as it typically starts with the best of intentions and ends up with the worst of consequences.”