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Using LLMs as judges for validating deal cash flow models: A new frontier in securitization modeling

As securitization models become increasingly complex and differentiated, validation becomes a critical challenge. We’ve experimented with an innovative approach that leverages large language models (LLMs) as impartial judges to validate models implemented across different platforms.

The Dual-Implementation Challenge

In cash flow modeling, we often maintain parallel implementations—typically in Python for flexibility and Excel for transparency. How do we ensure both versions produce consistent results?

Enter the “LLM as Judge” approach!

A Real-World Case Study: Residential Transition Loan Funding

Consider a portfolio of residential transition loans with a funding structure including:

  • 100 loans averaging $275,000 each
  • 12-month average terms at 8.75%
  • A 75% advance rate
  • 2% loss reserve build-up
  • Performance triggers based on delinquency rates

We implemented this structure in both Python and Excel, then submitted both models to an LLM for validation.

The LLM Validation Process

The LLM first analyzed the conceptual alignment between models, confirming both followed the same fundamental approach to cash flow projection, default assumptions, reserve mechanics, and triggers.

Next came a rigorous numerical comparison. The LLM detected a $100,000 investor distribution discrepancy in Month 2:

  • Python model: $1,790,702
  • Excel model: $1,690,702

Through logical analysis, the LLM determined this likely stemmed from differently evaluated trigger conditions. This kind of subtle implementation difference could easily go unnoticed in manual validation, potentially leading to significant valuation discrepancies over time.

Beyond Discrepancy Detection

The true power of this approach extends beyond finding differences. The LLM also provided:

  1. Stress testing recommendations tailored to our specific product, including scenarios for rapid defaults, extension waves, and interest rate shocks
  2. Model risk management insights highlighting documentation needs and suggesting a formal reconciliation process
  3. Code quality assessment noting strengths and weaknesses in both implementations

Why This Matters

For securitization professionals, this approach offers several advantages:

  • Efficiency: Automation of tedious line-by-line comparisons
  • Comprehensiveness: Identification of conceptual differences, not just numerical ones
  • Regulatory compliance: Better documentation for model risk management requirements
  • Objectivity: Unbiased third-party perspective

Contact us to discuss.


Mounting Pressure in Non-QM Credit: What March 2025 Data Signals for Risk Managers

This is a monthly update on non-QM delinquency rate and roll rate trends based on the March 2025 remittance data. Similar to last month’s post, I use the CoreLogic Non-Agency loan data to split out the Non-QM population by loan type. I compare the relative delinquency performance of mortgages backed by Investor properties vs. loans with full documentation vs. other Non-QM loan types (this last bucket comprises mainly Bank Statement loans). I use a slightly revised and more inclusive definition of Non-QM this month so the overall balance figures are higher and delinquency rates and roll rates are slightly lower than those reported in last month’s post.

The first chart shows that the non-performing delinquency rate (60+ dpd loans as a percentage of the overall population) has risen from a post-COVID low of 0.85% in July 2022 to 3.09% as for the most recent remit month. This increase has been driven by deterioration in the credit performance across all Non-QM loan types. Notably, the delinquency rate for Investor loans increased to 3.56% as of March, up more than three-fold from post-COVID lows of 1.1% in October 2022 and up 91bp year over year. Full Doc Non-QM loans continue to outperform other segments significantly, but their delinquency rates still rose to 0.85%, a new post COVID recovery high.

The other driver of the increase in delinquency rates for the Aggregate Non-QM loan population is a gradual shift in their mix away from the Full Doc loans, which have a better credit profile. As shown in the graph below, Full Doc loans as a percentage of the overall NQM mix have fallen from over 50% of NQM population as of the end of 2018 to only just under 31% in March. Meanwhile, Investor loans have increased from only 3% of the Non-QM population as of the end of 2018 to 10% just before COVID to over 24% as of March.


The last graph considers the gateway transition of mortgages to non-performing status: the current to 30 roll rates, or the percentage of current loans that roll to 30 days delinquent in any given month. These trends are broadly in line with what we see for the overall delinquency rates: roll rates have increased significantly since their post COVID lows.

In the March remittance data, overall Non-QM C->30 roll rates increased to 1.18%, their highest level since December 2020. All 3 non-QM segments broken out in this graph also hit new post COVID highs, with Investor-backed loans experiencing a 1.43% C->30 roll rate, 2.9x the 0.50% roll rate experienced by Full Doc Non-QM loans.


As non-QM mortgages show signs of growing distress amid broader economic uncertainty, we recommend heightened vigilance for investors and risk managers with Non-QM exposure in their portfolios. RiskSpan’s credit models forecast delinquency roll rates directly, and our modeling team calibrates our suite of models to capture both the overall trends and the differentiated performance across loan and product types. These models are just one component of our scaled analytics solutions to help our clients evaluate risk and make investment decisions.

Contact me to discuss.


From AI Hype to Helpful Assistant: AI Agents are coming soon to the RiskSpan Platform!

When agentic AI first hit the scene, we were intrigued—but skeptical. Was this just another over-hyped trend or something that could drive real value?

Fast forward a few months, and we’ve got our answer.

At RiskSpan, we’ve quietly integrated AI agents into our internal workflows through a dedicated Agent Desktop. These agents are now core to how we manage our business—monitoring client health, tracking system usage and perhaps most impressively, performing deep research across the massive datasets we store. What began as an experiment has become indispensable.

The real breakthrough is manifest, however, when Agents proactively uncover insights, flag anomalies, and automate routine analyses. Our Dev and Client teams are saving hours and making faster, more informed decisions because relevant information finds them.

Coming soon, our clients will be able to use Agents in the RiskSpan Platform to query their own data, analyze GSE performance data and run on-demand analysis instantly—all without waiting on a queue or building custom reports.

Designed for portfolio risk, surveillance, analyzing loan-level data, or exploring market trends, the AI agents will help you go from question to answer in seconds. Check out a sample below and reach out to learn more!


Non-QM Credit Stress by the Numbers: Investor and Full Doc Loan Performance Diverge

This is a follow-up to Bernadette Kogler’s short piece last month on stress in the Non-QM mortgage market. In this post, I use the CoreLogic Non-Agency loan data to split out the Non-QM population by loan type and look at the relative delinquency performance of mortgages backed by Investor properties vs. loans with full documentation vs. other Non-QM loan types (this last bucket comprises mainly Bank Statement loans).


As the following chart illustrates, the non-performing delinquency rate (60+ dpd loans as a percentage of the overall population) has risen from a post-COVID low of 1.01% to 3.59% as of March 2025. This increase has been driven by deterioration in the credit performance across all Non-QM loan types. Notably, the delinquency rate for Investor loans increased to 3.82% as of March, up more than three-fold from post-COVID lows of 1.1% in October 2022. While they remain the best performing loan type, even the Full Doc loans have seen a doubling of delinquency rate, to 1.11%.

The other driver of the sharp uptick in delinquency rates for the Aggregate Non-QM loan population is a shift in their mix away from the strongly performing Full Doc loans. As shown in the graph below, Full Doc loans as a percentage of the overall NQM mix have fallen from over 50% of NQM population as of the end of 2018 to only 22% in March. Meanwhile, Investor loans have increased from only 3% of the Non-QM population as of the end of 2018 to 10% just before COVID to 28% as of March.

Finally, we look at the gateway transition of mortgages to non-performing status: the current to 30 roll rates, or the percentage of current loans that roll to 30 days delinquent in any given month due to a missed payment. Not surprisingly, these trends are broadly in line with what we see for the overall delinquency rates: roll rates have increased significantly since their late 2022 lows.

But these roll rates give us a more real-time perspective on how different loan types are performing relative to each other than the delinquency rate levels, which represent the cumulative effect of historical performance. In the most recent remittance data, Investor-backed loans experienced a 1.42% C->30 roll rate, which was 2.5x the 0.58% roll rate experienced by Full Doc Non-QM loans. By contrast, that multiple was only 1.8x in October 2022 when NQM loans were experiencing their lowest post-COVID roll rate performance.

Given the deteriorating performance of Non-QM mortgages and backdrop of macroeconomic uncertainty, it is important for investors to monitor their portfolios that have Non-QM exposure. Our credit models at RiskSpan model these delinquency roll rates directly, and our modeling team calibrates our suite of models to capture both the overall trends and the differentiated performance across loan and product types. These models are just one component of our scaled analytics solutions to help our clients evaluate risk and make investment decisions.

Contact me to discuss.


The Future of Private Credit: Growth Challenges, and How RiskSpan is Leading the Way

Private credit is having a moment, as they say, now approaching $7 trillion in global assets, and is poised to double in size over the next decade. As traditional banks tighten lending due to regulatory constraints, private credit is stepping in to provide flexible, high-yield investment opportunities for institutional investors. However, this expanding market brings challenges, including illiquidity, bespoke deal structures, and complex risk assessments.

Chartis Research, in collaboration with RiskSpan, explores these evolving dynamics in a recent report, shedding light on the forces shaping private credit’s expansion and the critical role of technology in mitigating risk.

As private credit markets grow, effective risk management is crucial for investors seeking stable returns. Advanced technologies like AI and machine learning are revolutionizing private credit risk assessment, enhancing cash flow modeling, pricing accuracy, and portfolio diversification. RiskSpan leads the industry with innovative solutions, leveraging loan-level data and cloud-based platforms to provide real-time analytics. Whether you’re an asset manager, institutional investor, or lender, understanding the latest private credit trends is essential for success.

Read the full article to explore how private credit is transforming finance and why technology-driven risk management is the key to sustainable growth.

Contact us to learn more about how RiskSpan’s platform can support your private credit analytics.


Non-QM Delinquencies Are Rising—And Home Prices Aren’t Helping 📉

The non-QM mortgage market is showing clear signs of stress, and the latest delinquency data confirms it. RiskSpan analysis shows 60+ day delinquencies are rising, with 2022 and 2023 vintages deteriorating faster than prior years. Non-Qualified Mortgages (Non-QM) are loans that don’t meet traditional underwriting guidelines and often include self-employed borrowers, investors, and those with alternative income documentation.

What’s Driving the Spike?

Sustained higher mortgage rates have created pressure for some non-QM borrowers with fewer refinancing options. A more granular analysis shows loan attributes and risk layering driving high delinquencies, particularly those with cashout refi as the loan purpose. In a slowing home price appreciation (HPA) environment, borrowers who took out cash-out refis may be struggling with payment shock and limited home equity growth.

But the Real Problem? The Changing Housing Market.

Since the Covid crisis, many believed low housing inventory would keep prices elevated, but not anymore. The Wall Street Journal reported last week that housing inventory rose by 16% compared to the previous year. Further, the Federal Reserve Economic Data (FRED) shows 2024 HPA at just +3.5%, the slowest since 2020 with certain MSAs declining.  Florida remains its own unique case, while DC faces recession fears following recent Trump policy changes. 2025 looks even weaker – WS research projects HPA at just +2.5%, signaling even slower home price growth ahead.

The Risk: What Comes Next?

Slower home price growth means reduced equity cushions and borrowers with less ability to absorb financial shocks. This means refinancing and selling become less viable options leading to rising delinquencies & liquidity concerns. The markets could certainly stabilize or non-QM delinquencies could continue their upward climb.


AI-Powered Code Reviews

Our firm recently implemented a pilot that promises to dramatically accelerate our developer workflow by leveraging AI in code reviews. Feedback is now instant and actionable – and available in the very environments where our developers work.

The Problem: Time-consuming pull requests

A pull request is a developer’s proposal (after writing code to solve an issue/feature/bug) to merge changes in one branch of a code repository into (usually) the main branch. The resulting merged code is what gets promoted to production.

This is generally how junior developers submit code changes for review by more senior developers. These code reviews are critical but eat up a lot of senior developer time. Senior developers at RiskSpan face many of the same challenges as senior developers everywhere in that they juggle multiple priorities and struggle to find the time necessary to provide thorough, timely feedback on every pull request. This can lead to delays, inconsistent quality, and “technical debt” over time.

The Solution: An AI Merge Agent

At AWS re:Invent, we discovered Qodo Merge, an AI-powered tool that automates and enhances pull request reviews. Now live in our Bitbucket repositories, Qodo Merge:

  • Analyzes code changes and autogenerates pull request descriptions
  • Checks ticket compliance to ensure requirements are met
  • Flags security risks (e.g., command injection, cross-site scripting)
  • Suggests improvements in data processing, error handling, and logic
  • Provides real-time feedback, accelerating development cycles

Why this matters for our development lifecycle

This AI solution is revolutionizing and streamlining RiskSpan’s software development process by:

  • Standardizing our code review best practices
  • Reducing technical debt by enforcing quality baselines
  • Accelerating junior developers and making them more efficient by providing instant guidance
  • Freeing up senior engineers to focus their efforts on high-impact strategic work

What’s Next?

Having completed our initial pilot testing, we are now rolling out Qodo Merge across RiskSpan’s various code repositories. Next up: training sessions and broader adoption across all of our modeling and engineering teams.

AI is transforming how we build, validate, and deploy code. Stay tuned for insights on how this initiative is improving our development speed and quality!


Private Credit Primer Series: Insights for Investors

We are delighted to announce the release of RiskSpan’s series of Private Credit Primers aimed at providing investors with essential knowledge about the diverse and growing landscape of the loan types that private credit investors are buying. These primers offer at-a-glance insights into the mechanics, performance expectations, and unique features of various asset classes, enabling investors to make informed decisions in this dynamic market.

The first three primers in the series are available now: They focus on Residential Transition Loans (RTLs), Personal Loans, and HELOCs — loan types that are becoming increasingly popular in the private credit space.

Residential Transition Loans (RTLs) (full primer here)

RTLs are short-term loans designed to help borrowers bridge financial gaps during transitional periods in residential real estate. Often used for construction, bridge, and relocation purposes, RTLs typically have terms ranging from 6 to 36 months and feature higher interest rates than traditional long-term financing. These loans play a crucial role for both homeowners and real estate investors, especially in markets where property values fluctuate or where short-term liquidity is needed.

  • Important Features: RTLs often involve draw functionality, allowing borrowers to access funds incrementally as projects progress. Another key aspect is the use of the “As-Repaired” Value (ARV) to calculate Loan-to-Value (LTV) ratios, based on the projected value of the property after repairs.
  • Performance Considerations: While RTLs have performed well during periods of stable or rising home prices, the primer cautions that these loans are more vulnerable during economic downturns or periods of home price decline​.

Personal Loans (full primer here)

Personal loans can be secured or unsecured and are used for a variety of purposes, including debt consolidation, medical expenses, and large purchases. They are repaid in fixed monthly installments over a predetermined period.

  • Important Features: The primer highlights key modeling considerations for personal loans, such as static default/prepayment assumptions, which rely on historical data to predict future loan performance based on factors like loan age and borrower profiles.
  • Performance Expectations: As of 2024, the delinquency rate for personal loans stands at around 3.38%, with average interest rates hovering around 12.42%, though they can vary widely depending on market conditions and borrower credit quality​.

HELOCs (full primer here)

The complexity of modeling HELOCs stems from their sharing characteristics of both a mortgage and a credit card. Reliable assumptions about borrower behavior both during the draw period (when balances can move in either direction at any time) and during the post-draw, repayment-only period are crucial to forecasting correct cash flows.

  • Important Features: Understanding regional variations and borrower characteristics can provide deeper insights into HELOC performance, helping to refine risk models and lending strategies.
  • Performance Expectations: The delinquency rate for HELOCs can vary based on factors such as economic conditions, borrower credit quality, and market trends. However, historically, the delinquency rate for HELOCs tends to be lower than for unsecured loans or credit cards.

What to Expect from the Series

Each primer in the series will not only break down the mechanics of the loan type but also provide performance insights and modeling considerations. With the ongoing volatility in the financial markets, these primers will explore how various asset classes perform under different economic conditions, such as rising interest rates, declining home prices, or increasing unemployment.

By offering practical, data-driven insights, the Private Credit Primer series will serve as an invaluable resource for private credit investors who are looking to deepen their understanding of these asset classes and navigate potential risks effectively.

Stay tuned for more primers in this series, as we continues to expand RiskSpan’s library of resources for private credit investors!


Preparing For Impact: How Will Non-QM Prepay Speeds React to Lower Rates?

In a recent post, we addressed some of the less obvious ways in which a lower interest rate environment is likely to impact an agency universe with such a large volume of loans that are still out-of-the-money to refinance. In this post, we turn our attention to non-QM loans, whose unique characteristics mean they will likely feel the coming rate cuts differently.

Understanding the Distinctive Prepayment Dynamics of Non-QM Loans

Non-QM loans cater to borrowers who do not meet the stringent criteria of traditional agency loans, often due to factors like non-standard income documentation, credit issues, or investment property financing. Non-QM loans generally carry higher interest rates, and, unlike their agency counterparts, many have prepayment penalties designed to protect lenders from early payoff risk. Non-QM loans are also more likely than agency loans to involve investment properties – and thus, the underlying mortgages are not subject to the same “ability to repay” constraints that apply to agency/QM loans.

All these factors play a role in forecasting prepay speeds.

As rates decline, the incentive for some non-QM borrowers to refinance should increase, but several unique factors will shape the extent to which borrowers respond to this incentive:

  1. Prepayment Penalties: Many non-QM loans, especially those structured as Debt Service Coverage Ratio (DSCR) loans for investment properties, include prepayment penalties that can deter refinancing despite a favorable rate environment. These penalties vary widely, from a fixed percentage over a set period to declining penalties over time. The economic calculus for borrowers will hinge on whether the potential savings from refinancing outweigh these penalties
  2. Diverse Loan Structures: The non-QM market includes a variety of loan products, such as 40-year terms, hybrid ARMs and loans with interest-only periods, reminiscent of the pre-2008 lending landscape. This diversity means that not all non-QM loans will see the same incentive to refinance and the slope of the mortgage curve will matter. For example, loans with higher rates are likely to exhibit a stronger refinance response, particularly as the shape of the mortgage rate curve plays a significant role, with hybrid ARMs resetting off short-term rates and 30-year fixed-rate mortgages being influenced by movements in the 10-year Treasury yield
  3. Interest Rate Spread Compression: Historically, the spread between non-QM and agency mortgage rates has varied significantly, ranging from 100 to 300 basis points. A narrowing of this spread, driven by falling rates, could heighten the refinance incentive for non-QM borrowers, leading to faster prepayment speeds. However, the extent of this spread compression is uncertain and will depend on broader market dynamics. Souring economic conditions, for example, would likely contribute to a widening of spreads.

Key Factors Influencing Non-QM Prepayment Speeds

Loan Characteristics and Documentation Types

Non-QM loans can vary significantly by documentation type, such as full documentation, bank statements, or DSCR. Historically, as illustrated in the following chart, full documentation loans have shown faster prepayment speeds, because these borrowers are closer to qualifying for agency refinancing options as rates drop.

S-Curves by Doc Type (Full vs. Alt. vs. Bank Statement vs. DSCR)

Unlike agency mortgages, which include a substantial volume of loans originated at much lower rates, the non-QM market predominantly consists of loans originated in the past few years when rates were already elevated. As a result, a larger portion of non-QM loans is closer to being “in the money” for refinancing. This distinction suggests that the non-QM sector may see a more pronounced increase in prepayment activity compared to agency loans, where the lock-in effect remains stronger.

S-Curve (line) vs UPB (bars) by Refi Incentive

Economic Sensitivity to Rate Moves

For many non-QM borrowers, the primary barrier to agency loan qualification—whether credit score, income documentation, or property type—remains static despite lower rates. Thus, while a rate cut could improve the appeal of refinancing into another non-QM product, it might not significantly shift these borrowers towards agency loans. However, as noted, those closer to the threshold of agency eligibility could still be enticed to refinance if the rate spread and penalty structures align favorably.

Conclusion

The coming interest rate cuts are poised to influence the non-QM market in unique ways, with prepayment speeds likely to increase as borrowers seek to capitalize on lower rates. However, the interplay of rate spreads, prepayment penalties, and diverse loan structures will create a complex landscape where not all non-QM loans will behave uniformly. For lenders and investors, understanding these nuances is crucial to accurately forecasting prepayment risk and managing portfolios in a changing rate environment.

As the market evolves, ongoing analysis and model updates will be essential to capturing the shifting dynamics within the non-QM space, ensuring that investors and traders are well-prepared for the impacts of the anticipated rate cuts. Contact us to learn how RiskSpan’s Edge Platform is helping a growing number of non-QM investors get loan-level insights like never before.


Is Your Prepay Analysis Ready for the Rate Cut?

The forthcoming Federal Reserve interest rate cuts loom large in minds of mortgage traders and originators. The only remaining question is by how much rates will be cut. As the economy cools and unemployment rises, recent remarks by the Fed Chair have made the expectation of rate cuts essentially universal, with the market quickly repricing to a 50bp ease in September. This anticipated move by the Fed is already influencing mortgage rates, which have already experienced a notable decline.

Understanding the Lock-in Effect

One of the key factors influencing prepayments in the current environment is the lock-in effect, where borrowers are deterred from selling their current home due to the large difference between their current mortgage rate and prevailing market rates (which they would incur when purchasing their next home). As rates decrease, the gap narrows, reducing the lock-in effect and freeing more borrowers to sell and move.

As Chart 1 illustrates, a significant share of borrowers continues to hold mortgages between 2 and 3 percent. These borrowers clearly still have no incentive to refinance. But historical data suggests that the sizeable lock-in effect, which is currently depressing turnover, diminishes as the magnitude of their out-of-the-moneyness comes down. In other words, even a 100-basis point reduction can significantly increase housing turnover, as borrowers who were previously 300 basis points out of the money move to 200 basis points, making selling their old home and buying a new one, despite the higher interest rate, more palatable.

CHART 1: Distribution of Note Rates for 30-Year Conventional Mortgages: July 2024


Current Market Dynamics

Recent data from Mortgage News Daily indicates that mortgage rates have dropped over the past four weeks from around 6.8% to nearly 6.4%. This decrease is expected to continue, potentially bringing rates below 6% by the end of the year. This will likely have a profound impact on mortgage prepayments, particularly in the Agency MBS market.

Most outstanding mortgages, particularly those in Fannie and Freddie securities, currently have low prepayment speeds, with many loans sitting at 2% to 3% coupons. While a drop in mortgage rates to 6% (or lower) will still leave most of these mortgages out of the money for traditional rate-and-term refinances, it may bring a growing number of them into play for cash-out refinances, given significant home price appreciation and equity buildup over last 4 years. It will also loosen the grip of the lock-in effect for a growing number of homeowners currently paying below-market interest rates.

Implications for Prepayment Speeds

Factoring in the potential increase in turnover and cash-out refis, the impact of rate cuts on prepayment speeds could be substantial. For instance, with a 100-bp drop in rates, loans that are deeply out of the money could see their prepayment speeds increase by 1 to 2 CPR based on the turnover effect alone. Loans that are just at the money or slightly out of the money will see a more pronounced effect, with prepayment speeds potentially doubling. Chart 2, below, illustrates both the huge volume of loans deep out of the money to refinance as well as the small (but significant) uptick in CPR that a 100-bp shift in interest rates can have on CPR even for loans as much as 300 bps out of the money.

CHART 2: CPR by Refinance Incentive (dotted line reflects UPB of each bucket)


Historical data suggests that if mortgage rates move to 6.4%, the volume of loans moving into the money to refinance could increase up to eightfold — from $39 billion to $247 billion (see chart 3, below.) This surge in refinance activity will significantly influence prepays — impacting both turnover and refi volumes.

CHART 3: Volume and CPR by Coupon (dotted line reflects UPB of each bucket)


The Broader Housing Market

Beyond prepayments, the broader housing market may also feel the effects of rate cuts, but perhaps in a nuanced way. A reduction in rates generally improves affordability, potentially sustaining or even increasing home prices despite the increased supply from unlocked homes. However, this dynamic is complex. While lower rates make homes more affordable, the release of previously locked-in homes could counterintuitively depress home prices due to increased supply. With housing affordability at multi-decade lows, an uptick in housing supply could swamp any effect of somewhat lower rates.

While a modest rate cut may primarily boost turnover, a more significant cut could trigger a wave of refinancing. Additionally, cash-out refinances may become more attractive, offering a cheaper alternative to HELOCs and other more expensive options.

Conclusion

The forthcoming Fed interest rate cuts are poised to have a significant impact on mortgage prepayments. As rates decline, the lock-in effect will ease, encouraging more refinancing and increasing prepayment speeds. The broader housing market will also feel the effects, with potential implications for home prices and overall market dynamics. Monitoring these trends closely will be crucial for market participants, particularly those in the agency MBS market, as they navigate the changing landscape.

Contact us to staying informed and prepared and learn more about how RiskSpan can help you make strategic decisions that align with evolving market conditions.


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