October 28, 2013
S&P on Rating Mortgage-Backed Securities Before The Crisis
S&P has posted The Role of Credit Rating Agencies in The Financial System, remarks by its president at the United Nations. The remarks reflect S&P’s narrative of the events leading up to the Subprime Crisis. This narrative is, unsurprisingly, self-serving … Continue reading
October 28, 2013 in Regulation | Permalink | No Comments
October 23, 2013
Qualified Mortgage Fair Lending Concerns Quashed
Federal regulators (the FRB, CFPB, FDIC, NCUA and OCC) announced that “a creditor’s decision to offer only Qualified Mortgages would, absent other factors, elevate a supervised institution’s fair lending risk.” This announcement was intended to address lenders’ concerns that they … Continue reading
October 23, 2013 in Regulation | Permalink | No Comments
October 22, 2013
Private Capital and the Mortgage Markets
The American Securitization Forum recently wrote to the Federal Housing Finance Agency to argue for at least a small reduction in the size of the loans that Fannie and Freddie can guaranty. While this makes sense to me, it is … Continue reading
October 22, 2013 in Regulation | Permalink | No Comments
October 21, 2013
Access to Sustainable Credit
Reid & Quercia have posted Risk, Access and the QRM Reproposal. This document is intended to influence the most recent proposed rulemaking for the Qualified Residential Mortgages (QRMs). The rulemaking process for the QRM has been controversial and the stakes … Continue reading
October 21, 2013 in Regulation | Permalink | No Comments
October 18, 2013
Making Sense of Finance Charges
The Consumer Financial Protection Bureau has a very helpful Finance Charge Chart (page 13) in its Truth In Lending Act examination procedure manual. The manual is “intended for use by CFPB examiners in examining the mortgage companies and other financial … Continue reading
October 18, 2013 in Regulation | Permalink | No Comments
October 15, 2013
Mortgage Reform Schooling on 30 Year Term
S&P has posted U.S. Mortgage Finance Reform Efforts and the Potential Credit Implications to school us on the current state of affairs in Congress. It provides a useful lesson on three major mortgage reform bills introduced in Congress this year. … Continue reading
October 15, 2013 in Regulation | Permalink | No Comments
October 14, 2013
A HELOC of a Securitization
S&P posted A Look At U.S. Second-Lien And HELOC Transactions Post-Crisis. In 2008, they announced that “would halt rating new U.S. RMBS closed-end second-lien transactions because loan performance had deteriorated significantly. [They] haven’t rated any U.S. RMBS second-lien (both second-lien … Continue reading
October 14, 2013 in Regulation | Permalink | No Comments