Tag Archives: Goodman

Your Lender, The Federal Reserve Board

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photo by United States Federal Reserve

Federal Reserve Chair Yellen

Laurie Goodman and Bing Bai at the Urban Institute have posted Normalizing the Federal Reserve’s Balance Sheet The Impact on the Mortgage-Backed Securities Market. It is quite extraordinary to realize that the Federal Reserve owns nearly a third of outstanding residential mortgage-backed securities. When we think about the appropriate role of the government in the housing finance market, we cannot forget about this type of involvement. The paper opens,

During the crisis, the Federal Reserve found the traditional tools for monetary policy insufficient to stimulate the economy. From December 2008 to December 2015, the Fed’s primary policy tool, the target Fed funds rate, was set between 0 and 0.25 percent. But the economy remained weak, and there was no room to cut rates further. As a result, the Fed began to purchase large quantities of assets from the private sector. These programs are referred to as quantitative easing or large-scale asset purchases. The Fed owned $1.77 trillion of agency mortgage-backed securities (MBS) and $2.45 trillion of US Treasury securities (Treasuries) in late September 2017 and began to reduce the amount of these portfolio holdings in October 2017.

Some background: Since the Great Recession, the Fed has done three rounds of quantitative easing. From November 2008 to March 2010, it purchased $1.75 trillion in long-term Treasuries, Fannie Mae and Freddie Mac agency debentures, and agency mortgage-back securities (comprising Ginnie Mae, Fannie Mae, and Freddie Mac issuances). From November 2010 to June 2011, the Fed purchased an additional $600 billion of Treasuries. From September 2012 to September 2014, the Fed engaged in its third round of quantitative easing, initially purchasing $85 billion a month in Treasuries and agency debt and MBS, with $40 billion of agency MBS. The Fed began to taper its purchases in December 2013 and ended the program in October 2014. From October 2014 through September 2017, the Fed has reinvested its runoff. Through these actions, the Fed owned $1.77 trillion of agency MBS, nearly 29 percent of all outstanding MBS as of late September 2017.

The Federal Open Market Committee announced on September 20, 2017, that it would begin to normalize its balance sheet in October 2017. The committee has been transparent about the course. It will begin by reducing the reinvestment rates on its portfolio. In months 1 through 3, the Fed would let the System Open Market Account (SOMA) portfolio run off by $10 billion each month, increasing to $20 billion in months 4 through 6, $30 billion in months 6 through 9, $40 billion in months 10 through 12, and $50 billion a month thereafter. The maximum runoff in each month, if met, would comprise 60 percent Treasuries and 40 percent MBS. If there is not enough runoff in that month, the Fed will not sell to meet these targets.

Although this timetable is clear, additional questions arise about the MBS portfolio that the Fed should shed some light on. The largest questions include the following: What size and mix of assets does the Fed eventually want to hold? And how does it intend to get there? In this brief, we argue that this is not an academic exercise. When the Fed reaches its desired balance sheet size, it will hold approximately $1.18 trillion in mortgage assets. It will take a long time for these to run off if there is no selling. This may be fine, but the Fed has made several comments that indicate it could sell the “residual.” For example, the minutes of the September 2014 meeting includes the following statement:

The Committee currently does not anticipate selling agency mortgage-backed securities as part of the normalization process, although limited sales might be warranted in the longer run to reduce or eliminate residual holdings. The timing and pace of any sales would be communicated to the public in advance.

It is not at all clear what constitutes a “residual.”

This brief has four sections. The first shows that under assumptions reasonably close to what the Fed has used, there will still be close to $1.18 trillion of MBS on its books when the Fed balance sheet normalizes. We then review the arguments about the Fed’s long-term desired portfolio mix. If it is Treasuries only, this raises questions about whether and how quickly the Fed should change its mortgage and treasury mix to avoid making asset allocation decisions that distort financial markets. In the third section, we argue that the Fed should do some active portfolio management while they are still doing a small amount of reinvestment. Finally, we make the case that the Fed could play a costless and helpful role in launching the single government-sponsored enterprise (GSE) security. (1-2)

The paper raises some important policy questions:

There has been considerable discussion on what role mortgages should play in the Fed’s portfolio. There is general but not universal agreement that the Fed should not be in the asset allocation business over the long term because it distorts financial market prices. Lawrence White has stated that “government programs that divert credit away from the most productive uses, as evaluated by the marketplace, are inherently wasteful, even if policymakers have the best of intentions.” Charles Plosser, a former president of the Federal Reserve Bank of Philadelphia, sees additional dangers, noting that holding securities other than Treasuries opens the door for Congress (or the Fed) to use the balance sheet for political purposes. The Fed’s balance sheet could be “a huge intermediary and supplier of taxpayer subsidies to selected parties through credit allocation.” For example, if there was an infrastructure bill, the funds could be used to purchase the bonds that support the infrastructure initiative. Similarly, the funds could be used to purchase bonds to keep a municipality from defaulting. (9, citations omitted)

The Fed should address these policy questions head on, before any unintended consequences of such a dramatic policy intervention make themselves known.

How Tight Is The Credit Box?

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Laurie Goodman of the Urban Institute’s Housing Finance Policy Center has posted a working paper, Quantifying the Tightness of Mortgage Credit and Assessing Policy Actions. The paper opens,

Mortgage credit has become very tight in the aftermath of the financial crisis. While experts generally agree that it is poor public policy to make loans to borrowers who cannot make their payments, failing to make mortgages to those who can make their payments has an opportunity cost, because historically homeownership has been the best way to build wealth. And, default is not binary: very few borrowers will default under all circumstances, and very few borrowers will never default. The decision where to draw the line—which mortgages to make—comes down to what probability of default we as a society are prepared to tolerate.

This paper first quantifies the tightness of mortgage credit in historical perspective. It then discusses one consequence of tight credit: fewer mortgage loans are being made. Then the paper evaluates the policy actions to loosen the credit box taken by the government-sponsored enterprises (GSEs) and their regulator, the Federal Housing Finance Agency (FHFA), as well as the policy actions taken by the Federal Housing Administration (FHA), arguing that the GSEs have been much more successful than the FHA. The paper concludes with the argument that if we don’t solve mortgage credit availability issues, we will have a much lower percentage of homeowners because a larger share of potential new homebuyers will likely be Hispanic or nonwhite—groups that have had lower incomes, less wealth, and lower credit scores than whites. Because homeownership has traditionally been the best way for households to build wealth, the inability of these new potential homeowners to buy could increase economic inequality between whites and nonwhites. (1)

Goodman has been making the case for some time that the credit box is too tight. I would have liked to see a broader discussion in the paper of policies that could further loosen credit. What, for instance, could the Consumer Financial Protection Bureau do to encourage more lending? Should it be offering more of a safe harbor for lenders who are willing to make non-Qualified Mortgage loans? The private-label mortgage-backed securities sector has remained close to dead since the financial crisis.  Are there ways to bring some life — responsible life — back to that sector? Why aren’t portfolio lenders stepping into that space? What would they need to do so?

When the Qualified Mortgage rule was being hashed out, there was a debate as to whether there should be any non-Qualified Mortgages available to borrowers.  Some argued that every borrower should get a Qualified Mortgage, which has so many consumer protection provisions built into it. I was of the opinion that there should be a market for non-QM although the CFPB would need to monitor that sector closely. I stand by that position. The credit box is too tight and non-QM could help to loosen it up.

Fannie and Freddie’s Credit Risk Transfers

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The Urban Institute’s Housing Finance Policy Center has released its February 2017 Housing Finance at a Glance Chartbook, always a great resource for housing geeks. Each Chartbook highlights one topic. This one focuses on GSE credit risk transfers, an important but technical subject:

The GSE’s credit risk transfer (CRT) program is growing and tapping into a more diverse investor base, reducing the costs of CRTs and improving liquidity in this market. At the same time, the continued reliance on back-end transactions is cause for concern
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Freddie Mac‘s first two capital markets CRT transactions of 2017 have been different from previous Structured Agency Credit Risk (STACR) transactions in one important way. Unlike the pre-2017 deals, in which the first loss piece (Tranche B) was 100 basis points thick, the first loss piece (Tranche B2) in the latest transactions is only 50 basis points thick while second loss piece (B1) is also 50 basis points thick. Splitting the old B tranche more granularly in this manner is a noteworthy development for a few reasons.
Although this is hardly the first improvement the GSEs have made to their back-end CRT execution, it is an important one. Splitting the offering into more granular risk buckets will force investors to price the tranches more accurately, thus facilitating more precise price discovery of credit risk. More granular tranching will also help increase the demand for STACR securities. Investors who were previously willing, but unable to invest in the B tranche because investment guidelines prohibited them from taking first loss credit risk will now instead be able to invest in the second loss B1 tranche, which offers a higher expected returns than the previous second loss tranche (M2). Growing and diversifying the investor base is important because it makes the bidding process more efficient and minimizes the cost of risk transfer for Freddie Mac and the taxpayer. A larger, more diverse investor base also bodes well for the liquidity of the CRT market, which is still in its infancy.
Clearly, these innovations are important steps towards improving the efficiency of back-end CRT. But at the same time, they must be viewed in the context of the broader objectives of credit risk transfer and housing finance reform which have near unanimous support: reducing taxpayer risk, passing the benefits of CRT on to borrowers, facilitating broad availability of credit through the economic cycle, ensuring adequate access for lenders of all sizes, and promoting a variety of CRT executions, including at the front end to facilitate an understanding of which programs are most favorable under which circumstances.
Although the GSEs have experimented with front end mechanisms like lender recourse and deeper MI, these transactions have been few and far between, and with very little transparency about pricing and other terms. But more importantly, the GSEs’ continued and significant reliance on back-end capital markets transactions doesn’t put us on a path towards achieving some of the program objectives outlined above. This matters because it signals that the GSEs’ current strategy for credit risk transfer, which revolves largely around the success of back-end transactions, may ultimately keep the program from realizing its full potential. (5)
 So, all in all Fannie and Freddie are taking a step in the right direction, but it is just a small step on the road to housing finance reform.

Women Are Better Than Men,

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photo by Matt Neale

Greeks vs Amazons, Mausoleum of Halicarnassus, British Museum

at least at paying their mortgages. This is according to an Urban Institute research report that found that

It’s a fact: women on average pay more for mortgages. We are not the first people to have noticed this; a small number of other studies have also pointed it out (e.g., Cheng, Lin, and Liu 2011). One possible explanation is that women, particularly minority women, experience higher rates of subprime lending than their male peers (Fishbein and Woodall 2006; Phillips 2012; Wyly and Ponder 2011). Another explanation is that women tend to have weaker credit profiles (Van Rensselaer et al. 2013). We find that both these explanations are true and largely account for the higher rates.

Looking at loan performance for the first time by gender, however, we find that these weaker credit profiles do not translate neatly into weaker performance. In fact, when credit characteristics are held constant, women actually perform better than men. Nonetheless, since pricing is tied to credit characteristics not performance, women actually pay more relative to their actual risk than do men. Ironically, despite their better performance, women are more likely to be denied a mortgage than men. Given that more than one-third of female only borrowers are minorities and almost half of them live in low-income communities, we need to develop more robust and accurate measures of risk to ensure that we aren’t denying mortgages to women who are fully able to make good on their payments. (1)

This second paragraph undercuts the catchy title of the report, Women Are Better than Men at Paying Their Mortgage, because it is only true when comparing single women to single men and when credit characteristics are held constant.

The report confines its analysis to sole female and sole male borrowers, excluding two-borrower households. This limitation is compounded by the fact that the credit characteristics of men and women are not the same (as men have better credit characteristics as a group).  As a result of these limitations, I think the title of the report goes too far. The authors also acknowledge that the stakes are not that high because the “inequality does not translate into a significant amount that single women overpay for their mortgages: less than $150 per female-only borrower per loan.” (15)

That point aside, the report does raise an important issue about whether credit characteristics metrics are biased against women: “the dimensions we rely on to assess credit risk today do not adequately capture all the differences. This omission has real consequences.” (15) This is certainly true, but lenders will have to carefully navigate fair lending laws as they seek to capture all of those differences.

Accurately Measuring Mortgage Availability

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The Urban Institute’s Housing Finance Policy Center has posted a research report, Measuring Mortgage Credit Availability Using Ex-Ante Probability of Default. This report tackles an important subject:

How to strike a balance between credit availability and risk to achieve a sustainable housing market is a much-debated topic today, but these discussions are not grounded in good measurements of credit availability and risk. We address this problem below with a new index that measures credit availability and risk simultaneously

The first section of the paper discusses the limitations of the existing measures. The second section describes our development of the new index, which distills borrower credit profiles, loan products and terms, and macro economic conditions into a measurement of the weighted average probability of default for mortgages originated at a given time. The third section illustrates the value of this measure by empirically exploring the varying risk appetites of the market as a whole, and of market segments, which directly aids evidence-based policymaking on how to open the tight credit box. The final section discusses the limitations of this new index. (1)
The report concludes,
Measuring a concept as complicated and varied as credit access is no easy task. Yet this is an important time to ensure that it is being measured accurately. As we seek to reform the housing finance system, Congress, the housing finance industry, advocacy groups, policymakers, and even the general public need to clearly understand how well the market is providing access to mortgage credit for borrowers. (18)
I say amen to that. There is a slim chance that housing finance reform may be back on the table in Washington, given the midterm election results. We need as much good data we can get in order to structure a system based on solid principles rather than on the views of special interests that typically dominate this debate.
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Top Ten Issues for Housing Finance Reform

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Laurie Goodman of the Urban Institute has posted A Realistic Assessment of Housing Finance Reform. This paper is quite helpful, given the incredible complexity of the topic. The paper includes a lot of background, but I assume that readers of this blog are familiar with that.  Rather, let me share her Top Ten Design Issues:

  1. What form will the private capital that absorbs the first loss take: A single guarantor (a utility), multiple guarantors, or multiple guarantors along with capital markets execution? How much capital will be required?
  2. Who will play what role in the system? Will the same entity be permitted to be an originator, aggregator, and guarantor?
  3. How will the system ensure that historically underserved borrowers and communities are well served? To what extent will the pricing be cross subsidized?
  4. Who will have access to the new government-backed system (loan limits)? How big should the credit box be, and how does that box relate to FHA?
  5. Will mortgage insurance be separate from the guarantor function? (It is separate under most proposals, but in reality both sets of institutions are guaranteeing credit risk. The separation is a relic of the present system, in which, by charter, the GSEs can’t take the first loss on any mortgage above 80 LTV. However, if you allow the mortgage insurers and the guarantors to be the same entity, capital requirements must be higher to adequately protect the government and, ultimately, the taxpayers.)
  6. How will small lenders access the system? (All proposals attempt to ensure access, some through an aggregator dedicated to smaller lenders—a role that the Home Loan Banks can play.)
  7. What countercyclical features should be included? If the insurance costs provided by the guarantors are “too high” should the regulatory authority be able to adjust capital levels down to bring down mortgage rates? Should the regulatory authority be able to step in as an insurance provider?
  8. Will multifamily finance be included? How will that system be designed? Will it be separate from the single-family business? (The multifamily features embedded in Johnson-Crapo had widespread bipartisan support, but the level of support for a stand-alone multifamily legislation is unclear.)
  9. The regulatory structure for any new system is inevitably complex. Who charters new guarantors? What are the approval standards? Who does the stress tests? How does the new regulator interact with existing regulators? What enforcement authority will it have concerning equal access goals? What is the extent of data collection and publication?
  10. What does the transition look like? How do we move from a duopoly to more guarantors? Will Fannie and Freddie turn back to private entities and operate as guarantors alongside the new entrants? How will the new entities be seeded? What is the “right” number of guarantors, and how do we achieve that? How quickly does the catastrophic insurance fund build? (16-17)

None of this is new, but it is nice to see it all in one place. These design issues need to thought about in the context of the politics of housing reform as well — what system is likely to maintain its long-term financial health and stay true to its mission, given the political realities of Washington, D.C.?

Speaking of politics, her prognosis for reform in the near term is not too hopeful:

The current state of the GSEs can best be summed up in a single word: limbo. Despite the fact that Fannie Mae and Freddie Mac were placed in conservatorship in 2008, with the clear intent that they not emerge, there is little progress on a new system, with a large role for private capital, to take their place. Legislators have realized it is easy to agree on a set of principles for a new system but much harder to agree on the system’s design. It is unclear whether any legislation will emerge from Congress before the 2016 election; there is a good chance there will be none. (26)

She does allow that the FHFA can administratively move housing finance reform forward to some extent on its own, but she rightly notes that reform is really the responsibility of Congress. Like Goodman, I am not too hopeful that Congress will act in the near term. But it is crystal clear that there is a cost of doing nothing. In all likelihood, it will be the taxpayer will pay that cost, one way or another.

Housing Finance at A Glance

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The Urban Institute’s Housing Finance Policy Center really does give a a nice overview of the American housing finance system in its monthly chartbook, Housing Finance at A Glance. I list below a few of the charts that I found particularly informative, but I recommend that you take a look at the whole chartbook if you want to get a good sense of what it has to offer:

  • First Lien Origination Volume and Share (reflecting market share of Bank portfolio; PLS securitization; FHA/VA securitization; an GSE securitization)
  • Mortgage Origination Product Type (by Fixed-rate 30-year mortgage; Fixed-rate 15-year mortgage; Adjustable-rate mortgage; Other)
  • Securitization Volume and Composition (by Agency and Non-Agency Share of Residential MBS Issuance)
  • National Housing Affordability Over Time
  • Mortgage Insurance Activity (by VA, FHA, Total private primary MI)

As with the blind men and the elephant, It is hard for individuals to get their  hands around the entirety of the housing finance system. This chartbook makes you feel like you got a glimpse of it though, at least a fleeting one.