How Do You Rate on Fannie Mae’s New Social Index? Quick take-aways HMDA data contains nearly every factor needed to replicate Fannie Mae’s Single Family Social Index. We use this data to explore how the methodology would look if the Fannie Mae Social Index were applied to other market participants. The Agencies and Ginnie Mae are not the only game Read More.. https://riskspan.com/how-do-you-rate-on-fannie-maes-new-social-index/ Quick take-aways HMDA data contains nearly every factor needed to replicate Fannie Mae’s Single Family Social Index. We use this data to explore how the methodology would look if the Fannie Mae Social Index were applied to other market participants. The Agencies and Ginnie Mae are not the only game in town when it comes socially responsible lending. Non-agency loans would also perform reasonably well under Fannie Mae’s proposed Social Index. Not surprisingly, Ginnie Mae outperforms all other “purchaser types” under the framework, buoyed by its focus on low-income borrowers and underserved communities. The gap between Ginnie and the rest of the market can be expected to expand in low-refi environments. With a few refinements to account for socially responsible lending beyond low-income borrowers, Fannie Mae’s framework can work as a universally applicable social measure across the industry. Fannie Mae’s new “Single Family Social Index” Last week, Fannie Mae released a proposed methodology for its “Single Family Social Index.” The index is designed to provide “socially conscious investors” a means of “allocat[ing] capital in support of affordable housing and to provide access to credit for underserved individuals.” The underlying methodology is simple enough. Each pool of mortgages receives a score based on how many of its loans meet one or more specified “social criteria” across three dimensions: borrower income, borrower characteristics and property location/type. Fannie Mae succinctly illustrates the defined criteria and framework in the following overview deck slide. Figure 1: Source: Designing for Impact — A Proposed Methodology for Single-Family Social Disclosure Each of the criteria is binary (yes/no) which facilitates the scoring. Individual loans are simply rated based on the number of boxes they check. Pools are measured in two ways: 1) a “Social Criteria Share,” which identifies the percentage of loans that meet any of the criteria, and 2) a “Social Density Score,” which assigns a “Social Score” of 0 thru 3 to each individual loan based on how many of the three dimensions (borrower income, borrower characteristics, and property characteristics) it covers and then averaging that score across all the loans in the pool. If other issuers adopt this methodology, what would it look like? The figure below is one of many charts and tables provided by Fannie Mae that illustrate how the Index works. This figure shows the share of acquisitions meeting one or more of the Social Index criteria (i.e., the overall “Social Criteria Share.” We have drawn a box approximately around the 2020 vintage, which appears to have a Social Criteria Share of about 52% by loan count. We will refer back to this value later as we seek to triangulate in on a Social Criteria Share for other market participants. SPEAK TO AN EXPERT Figure 2: Source: Designing for Impact — A Proposed Methodology for Single-Family Social Disclosure We can get a sense of other issuers’ Social Criteria Share by looking at HMDA data. This dataset provides everything we need to re-create the Index at a high-level, with the exception of a flag for first time home buyers. The process involves some data manipulation as several Index criteria require us to connect to two census-tract level data sources published by FHFA. HMDA allows us break down the loan population by purchaser type, which gives us an idea of each loan’s ultimate destination—Fannie, Freddie, Ginnie, etc. The purchaser type does not capture this for every loan, however, because originators are only obligated to report loans that are closed and sold during the same calendar year. The two tables below reflect two different approaches to approximating the population of Fannie, Freddie, and Ginnie loans. The left-hand table compares the 2020 origination loan count based on HMDA’s Purchaser Type field with loan counts based on MBS disclosure data pulled from RiskSpan’s Edge Platform. The right-hand table enhances this definition by first re-categorizing as Ginnie Mae all FHA/VA/USDA loans with non-agency purchaser types. It also looks at the Automated Underwriting System field and re-maps all owner-occupied loans previously classified as “Other or NA” to Fannie (DU AUS) or Freddie (LP/LPA AUS). The adjusted purchaser type approach used in the right-hand table reallocates a considerable number of “Other or NA” loans from the left-hand table. The approach clearly overshoots the Fannie Mae population, as some loans underwritten using Fannie’s automated underwriting system likely wind up at Freddie and other segments of the market. This limitation notwithstanding, we believe this approximation lends a more accurate view of the market landscape than does the unadjusted purchaser type approach. We consequently rely primarily on the adjusted approach in this analysis. Given the shortcomings in aligning the exact population, the idea here is not to get an exact calculation of the Social Index metrics via HMDA, but to use HMDA to give us a rough indication of how the landscape would look if other issuers adopted Fannie’s methodology. We expect this to provide a rough rank-order understanding of where the richest pools of ‘Social’ loans (according to Fannie’s methodology) ultimately wind up. Because the ultimate success of a social scoring methodology can truly be measured only to the extent it is adopted by other issuers, having a universally useful framework is crucial. The table below estimates the Social Criteria Share by adjusted purchaser using seven of Fannie Mae’s eight social index criteria. Not surprisingly, Ginnie, Fannie, and Freddie boast the highest overall shares. It is encouraging to note, however, that other purchaser types also originate significant percentages of socially responsible loans. This suggests that Fannie’s methodology could indeed be applied more universally. The table looks at each factor separately and could warrant its own blog post entirely to dissect, so take a closer look at the dynamics. Ginnie Mae’s strong performance on the Index comes as no surprise. Ginnie pools, after all, consist primarily of FHA loans, which skew toward the lower end of the income spectrum, first-time borrowers, and traditionally underserved communities. Indeed, more than 56 percent of Ginnie Mae loans tick at least one box on the Index. And this does not include first-time homebuyers, which would likely push that percentage even higher. Income’s Outsized Impact Household income contributes directly or indirectly to most components of Fannie’s Index. Beyond the “Low-income” criterion (borrowers below 80 percent of adjusted median income), nearly every other factor favors income levels be below 120 percent of AMI. Measuring income is tricky, especially outside of the Agency/Ginnie space. The non-Agency segment serves many self-employed borrowers, borrowers who qualify based on asset (rather than income) levels, and foreign national borrowers. Nailing down precise income has historically proven challenging with these groups. Given these dynamics, one could reasonably posit that the 18 percent of PLS classified as “low-income” is actually inflated by self-employed or wealthier borrowers whose mortgage applications do not necessarily reflect all of their income. Further refinements may be needed to fairly apply the Index framework to this and market segments that pursue social goals beyond expanding credit opportunities for low-income borrowers. This could just be further definitions on how to calculate income (or alternatives to the income metric when not available) and certain exclusions from the framework altogether (foreign national borrowers, although these may be excluded already based on the screen for second homes). Positive effects of a purchase market The Social Criteria Share is positively correlated with purchase loans as a percentage of total origination volume (even before accounting for the FTHB factor). This relationship is apparent in Fannie Mae’s time series chart near the top of this post. Shares clearly drop during refi waves. Our analysis focuses on 2020 only. We made this choice because of HMDA reporting lags and the inherent facility of dealing with a single year of data. The table below breaks down the HMDA analysis (referenced earlier) by loan purpose to give us a sense for what our current low-refi environment could look like. (Rate/term refis are grouped together with cash-out refis.) As the table below indicates, Ginnie Mae’s SCS for refi loans is about the same as it is for GSE refi loans — it’s really on purchase loans where Ginnie shines. This implies that Ginnie’s SCS will improve even further in a purchase rate environment. Accounting for First-time Homebuyers As described above, our methodology for estimating the Social Criteria Share omits loans to first-time homebuyers (because the HMDA data does not capture it). This likely accounts for the roughly 6 percentage point difference between our estimate of Fannie’s overall Social Criteria Share for 2020 (approximately 46 percent) and Fannie Mae’s own calculation (approximately 52 percent). To back into the impact of the FTHB factor, we can pull in data about the share of FTHBs from RiskSpan’s Edge platform. The chart above that looks a Purchase vs. Refi tells us the SCS share without the FTHB factor for purchase loans. Using MBS data sources, we can obtain the share of 2020 originations that were FTHBs. If we assume that FTHB loans look the same as purchase loans overall in terms of how many other Social Index boxes they check, then we can back into the overall SCS incorporating all factors in Fannie’s methodology. Applying this approach to Ginnie Mae, we conclude that, because 29 percent of Ginnie’s purchase loans (one minus 71 percent) do not tick any of the Index’s boxes, 29 percent of FTHB loans (which account for 33 percent of Ginnie’s overall population) also do not tick any Index boxes. Taking 29 percent of this 33 percent results in an additional 9.6 percent that should be tacked on to Ginnie Mae’s pre-FTHB share, bringing it up to 66 percent. Validating this estimation approach is the fact it increases Fannie Mae’s share from 46 percent (pre-FTHB) to 52 percent, which is consistent with the historical graph supplied by Fannie Mae (see Figure 2, above). Our FTHB approach implies that 92 percent of Ginnie Mae purchase loans meet one or more of the Index criteria. One could reasonably contend that Ginnie Mae FTHB loans might be more likely than Ginnie purchase loans overall to satisfy other social criteria (i.e., that 92 percent is a bit rich), in which case the 66 percent share for Ginnie Mae in 2020 might be overstated. Even if we mute this FTHB impact on Ginnie, however, layering FTHB loans on top of a rising purchase-loan environment would likely put today’s Ginnie Mae SCS in the low 80s.  The chart is organized by acquisition month, our analysis of HMDA looks at 2020 originations, so we’ve tried to push the box slightly to the right to reflect the 1–3-month lag between origination and acquisition. Additionally, we think the chart and numbers throughout Fannie’s document are just Fixed Rate 30 loans, our analysis includes all loans. We did investigate what our numbers would look like if filtered to Fixed 30 and it would only increase the SCS slightly across the board.  As noted above, we are unable to discern first-time homebuyer information from the HMDA data.  We can compare the Fannie numbers for each factor to published rates in their documentation representing the time period 2017 forward. The only metric where we stand out as being meaningfully off is the percentage of loans in minority census tracts. We took this flag from FHFA’s Low-Income Area File for 2020 which defines a minority census tract having a ‘…minority population of at least 30 percent and a median income of less than 100 percent of the AMI.’ It is not 100% clear that this is what Fannie Mae is using in its definition.