Why Climate Risk Matters for Mortgage Loan & MSR Investors
The time has come for mortgage investors to start paying attention to climate risk.
Until recently, mortgage loan and MSR investors felt that they were largely insulated from climate risk. Notwithstanding the inherent risk natural hazard events pose to housing and the anticipated increased frequency of these events due to climate change, it seemed safe to assume that property insurers and other parties in higher loss position were bearing those risks.
In reality, these risks are often underinsured. And even in cases where property insurance is adequate, the fallout has the potential to hit investor cash flows in a variety of ways. Acute climate events like hurricanes create short-term delinquency and prepayment spikes in affected areas. Chronic risks such as sea level rise and increased wildfire risk can depress housing values in areas most susceptible to these events. Potential impacts to property insurance costs, utility costs (water and electricity in areas prone to excessive heat and drought, for example) and property taxes used to fund climate-mitigating infrastructure projects all contribute to uncertainty in loan and MSR modeling.
Moreover, dismissing climate risk “because we are in fourth loss position” should be antithetical to any investor claiming to espouse ESG principles. After all, consider who is almost always in the first loan position – the borrower. Any mortgage investment strategy purporting to be ESG friendly must necessarily take borrower welfare into account. Dismissing climate risk because borrowers will bear most of the impact is hardly a socially responsible mindset. This is particularly true when a disproportionate number of borrowers prone to natural hazard risk are disadvantaged to begin with.
Hazard and flood insurers typically occupy the loss positions between borrowers and investors. Few tears are shed when insurers absorb losses. But society at large ultimately pays the price when losses invariably lead to higher premiums for everybody.
Evaluating Climate Exposure
For these and other reasons, natural hazards pose a systemic risk to the entire housing system. For mortgage loan and MSR investors, it raises a host of questions. Among them:
- What percentage of the loans in my portfolio are susceptible to flood risk but uninsured because flood maps are out of date?
- How geographically concentrated is my portfolio? What percentage of my portfolio is at risk of being adversely impacted by just one or two extreme events?
- What would the true valuation of my servicing portfolio be if climate risk were factored into the modeling?
- What will the regulatory landscape look like in coming years? To what extent will I be required to disclose the extent to which my portfolio is exposed to climate risk? Will I even know how to compute it, and if so, what will it mean for my balance sheet?
Incorporating Climate Data into Investment Decision Making
Forward-thinking mortgage servicers are at the forefront of efforts to get their arms around the necessary data and analytics. Once servicers have acquired a portfolio, they assess and triage their loans to identify which properties are at greatest risk. Servicers also contemplate how to work with borrowers to mitigate their risk.
For investors seeking to purchase MSR portfolios, climate assessment is making its way into the due diligence process. This helps would-be investors ensure that they are not falling victim to adverse selection. As investors increasingly do this, climate assessment will eventually make its way further upstream, into appraisal and underwriting processes.
Reliably modeling climate risk first requires getting a handle on how frequently natural hazard events are likely to occur and how severe they are likely to be.
In a recent virtual industrial roundtable co-hosted by RiskSpan and Housing Finance Strategies, representatives of Freddie Mac, Mr. Cooper, and Verisk Analytics (a leading data and analytics firm that models a wide range of natural and man-made perils) gathered to discuss why understanding climate risk should be top of mind for mortgage investors and introduced a framework for approaching it.
Building the Framework
The framework begins by identifying the specific hazards relevant to individual properties, building simulated catalogs of thousands of years’ worth of simulated events, computing likely events simulating damage based on property construction and calculating likely losses. These forecasted property losses are then factored into mortgage performance scenarios and used to model default risk, prepayment speeds and home price impacts.

Responsibility to Borrowers
One member of the panel, Kurt Johnson, CRO of mega-servicer Mr. Cooper, spoke specifically of the operational complexities presented by climate risk. He cited as one example the need to speak daily with borrowers as catastrophic events are increasingly impacting borrowers in ways for which they were not adequately prepared. He also referred to the increasing number of borrowers incurring flood damage in areas that do not require flood insurance and spoke to how critical it is for servicers to know how many of their borrowers are in a similar position.
Johnson likened the concept of credit risk layering to climate risk exposure. The risk of one event happening on the heels of another event can cause the second event to be more devastating than it would have been had it occurred in a vacuum. As an example, he mentioned how the spike in delinquencies at the beginning of the covid pandemic was twice as large among borrowers who had just recovered from Hurricane Harvey 15 months earlier than it was among borrowers who had not been affected by the storm. He spoke of the responsibility he feels as a servicer to educate borrowers about what they can do to protect their properties in adverse scenarios.
FHFA Prepayment Monitoring Reports (Q1 2022) Powered by RiskSpan’s Edge Platform
To help enforce alignment of Agency prepayments across Fannie’s and Freddie’s Uniform MBS, the Federal Housing Finance Agency publishes a quarterly monitoring report. This report compares prepayment speeds of UMBS issued by the two Agencies. The objective is to help ensure that prepayment performance remains consistent. This consistency ensures that market expectations of a Fannie-issued UMBS are fundamentally indistinguishable from those of a Freddie-issued UMBS. The two Agencies’ UMBS should be interchangeably deliverable into passthrough “TBA” trades.
This week, the FHFA released the Q1 2022 version of this report. The charts in the FHFA’s publication, which it generates using RiskSpan’s Edge Platform, compare Fannie and Freddie UMBS prepayment rates (1-month and 3-month CPRs) across a variety of coupons and vintages.



Relying on RiskSpan’s Edge Platform for this sort of analysis is fitting in that it is precisely the type of comparative analysis for which Edge was developed.
Edge allows traders, portfolio managers, and analysts to compare performance across a virtually unlimited number of loan subgroups. Users can cohort on multiple loan characteristics, including servicer, vintage, loan size, geography, LTV, FICO, channel, or any other borrower characteristic.
Edge’s easy-to-navigate user interface makes it accessible to traders and PMs seeking to set up queries and tweak constraints on the fly without having to write SQL code. Edge also offers an API for users that want programmatic access to the data. This is useful for generating customized reporting and systematic analysis of loan sectors.
Comparing Fannie’s and Freddie’s prepay speeds only scratches the surface of Edge’s analytical capabilities. Schedule a demo to see more of what the platform can do.
Senior Home Equity Rises Again to $10.6 Trillion
Homeowners 62 and older saw their housing wealth grow by some $405 billion (3.8 percent) during the fourth quarter of 2021 to a record $10.6 trillion according to the latest quarterly release of the NRMLA/RiskSpan Reverse Mortgage Market Index.

The NRMLA/RiskSpan Reverse Mortgage Market Index (RMMI) rose to 370.56, another all-time high since the index was first published in 2000. The increase in older homeowners’ wealth was mainly driven by an estimated $452 billion (3.7 percent) increase in home values, offset by a $44 billion (2.3 percent) increase in senior-held mortgage debt.
For a comprehensive commentary, please see NRMLA’s press release.
How RiskSpan Computes the RMMI
To calculate the RMMI, RiskSpan developed an econometric tool to estimate senior housing value, mortgage balances, and equity using data gathered from various public resources. These resources include the American Community Survey (ACS), Federal Reserve Flow of Funds (Z.1), and FHFA housing price indexes (HPI). The RMMI represents the senior equity level at time of measure relative to that of the base quarter in 2000.[1]
A limitation of the RMMI relates to Non-consecutive data, such as census population. We use a smoothing approach to estimate data in between the observable periods and continue to look for ways to improve our methodology and find more robust data to improve the precision of the results. Until then, the RMMI and its relative metrics (values, mortgages, home equities) are best analyzed at a trending macro level, rather than at more granular levels, such as MSA.
[1] There was a change in RMMI methodology in Q3 2015 mainly to calibrate senior homeowner population and senior housing values observed in 2013 American Community Survey (ACS).
Surge in Cash-Out Refis Pushes VQI Sharply Higher



A sharp uptick in cash-out refinancing pushed RiskSpan’s Vintage Quality Index (VQI) to its highest level since the first quarter of 2019.
RiskSpan’s Vintage Quality Index computes and aggregates the percentage of Agency originations each month with one or more “risk factors” (low-FICO, high DTI, high LTV, cash-out refi, investment properties, etc.). Months with relatively few originations characterized by these risk factors are associated with lower VQI ratings. As the historical chart above shows, the index maxed out (i.e., had an unusually high number of loans with risk factors) leading up to the 2008 crisis.
RiskSpan uses the index principally to fine-tune its in-house credit and prepayment models by accounting for shifts in loan composition by monthly cohort.

Rising Rates Mean More Cash-Out Refis (and more risk)
As the following charts plotting the individual VQI components illustrate, a spike in cash-out refinance activity (as a percentage of all originations) accounted for more of the rise in overall VQI than did any other risk factor.
This comes as little surprise given the rising rate environment that has come to define the first quarter of 2022, a trend that is likely to persist for the foreseeable future.
As we demonstrated in this recent post, the quickly vanishing number of borrowers who are in the money for a rate-and-term refinance means that the action will increasingly turn to so-called “serial cash-out refinancers” who repeatedly tap into their home equity even when doing so means refinancing into a mortgage with a higher rate. The VQI can be expected to push ever higher to the extent this trend continues.
An increase in the percentage of loans with high debt-to-income ratios (over 45) and low credit scores (under 660) also contributed to the rising VQI, as did continued upticks in loans on investment and multi-unit properties as well as mortgages with only one borrower.









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Population assumptions:
- Monthly data for Fannie Mae and Freddie Mac.
- Loans originated more than three months prior to issuance are excluded because the index is meant to reflect current market conditions.
- Loans likely to have been originated through the HARP program, as identified by LTV, MI coverage percentage, and loan purpose, are also excluded. These loans do not represent credit availability in the market as they likely would not have been originated today but for the existence of HARP.
Data assumptions:
- Freddie Mac data goes back to 12/2005. Fannie Mae only back to 12/2014.
- Certain fields for Freddie Mac data were missing prior to 6/2008.
GSE historical loan performance data release in support of GSE Risk Transfer activities was used to help back-fill data where it was missing.
An outline of our approach to data imputation can be found in our VQI Blog Post from October 28, 2015.
Data Source: Fannie Mae PoolTalk®-Loan Level Disclosure
EDGE: Cash-Out Refi Speeds
Mortgage rates have risen nearly 200bp from the final quarter of 2021, squelching the most recent refinancing wave and leaving the majority of mortgage holders with rates below the prevailing rate of roughly 5% (see chart below). For most homeowners, it no longer makes sense to refinance an existing 30yr mortgage into another 30yr mortgage.

But, as we noted back in February, the rapid rise in home prices has left nearly all households with significant, untapped gains in their household balance sheets. For homeowners with consumer debt at significantly higher rates than today’s mortgage rates, it can make economic sense to consolidate debt using a cash-out refi loan against their primary residence. As we saw during 2002-2003, cash-out refinancing can drive speeds on discount mortgages significantly higher than turnover alone. Homeowners can also become “serial cash-out refinancers,” tapping additional equity multiple times.
In this analysis, we review prepayment speeds on cash-out refis, focusing on discount MBS, i.e., mortgages whose note rates are equal to or below today’s prevailing rates.
The volume of cash-out refis has grown steadily but modestly since the start of the pandemic, whereas rate/term refis surged and fell dramatically in response to changing interest rates. Despite rising rates, the substantial run-up in home prices and increased staffing at originators from the recent refi boom has left the market ripe for stronger cash-out activity.
The pivot to cash-out issuance is evidenced by the chart below, illustrating how the issuance of cash-out refi loans (the black line below) in the first quarter of this year was comparable with issuance in the summer of 2021, when rates near historic lows, while rate/term refis (blue line) have plunged over the same period.

With cash-out activity set to account for a larger share of the mortgage market, we thought it worthwhile to compare some recent cash-out activity trends. For this analysis, the graphs consist of truncated S-curves, showing only the left-hand (out-of-the-money) side of the curve to focus on discount mortgage behavior in a rising rate environment where activity is more likely to be influenced by serial cash-out activity.
This first chart compares recent performance of out-of-the money mortgages by loan purpose, comparing speeds for purchase loans (black) with both cash-out refis (blue) and rate/term refis (green). Notably, cash-out refis offer 1-2 CPR upside over rate/term refis, only converging to no cash out refis when 100bp out of the money.[1]
Next, we compare cash-out speeds by servicer type, grouping mortgages that are serviced by banks (blue) versus mortgages serviced by non-bank servicers (green). Non-bank servicers produce significantly faster prepay speeds, an advantage over bank-serviced loans for MBS priced at a discount.
Finally, we drill deeper into the faster non-bank-serviced discount speeds for cash-out refis. This chart isolates Quicken (red) from other non-bank servicers (green). While Quicken’s speeds converge with those of other non-banks at the money, Quicken-serviced cash-out refis are substantially faster when out of the money than both their non-bank counterparts and the cash-out universe as a whole.[2]
We suspect the faster out-of-the-money speeds are being driven by serial cash-out behavior, with one servicer in particular (Quicken) encouraging current mortgage holders to tap home equity as housing prices continue to rise.
This analysis illustrates how pools with the highest concentration of Quicken-serviced cash-out loans may produce substantially higher out-of-the-money speeds relative to the universe of non-spec pools. To find such pools, users can enter a list of pools into the Edge platform and simultaneously filter for both Quicken and cash-out refi. The resultant query will show each pool’s UPB for this combination of characteristics.
EDGE: Recent Performance of GNMA RG Pools
In early 2021, GNMA began issuing a new class of custom pools with prefix “RG.” These pools are re-securitizations of previously delinquent loans which were repurchased from pools during the pandemic.[1] Loans in these pools are unmodified, keeping the original rate and term of the mortgage note. In the analysis below, we review the recent performance of these pools at loan-level detail. The first RG pools were issued in February 2021, growing steadily to an average rate of $2B per month from Q2 onward, with a total outstanding of $21 billion.

The majority of RG issuance has included loans that are two to seven years seasoned and represent a consistent 2-3% of the total GNMA market for those vintages, dashed line below.

Coupons of RG pools are primarily concentrated between 3.0s through 4.5s, with the top-10 Issuers of RG pools account for nearly 90% of the issuance.

Below, we compare speeds on GNMA RG pools under various conditions. First, we compare speeds on loans in RG pools (black) versus same-age multi-lender pools (red) over the last twelve months. When out of the money, RG pools are 4-5 CPR slower than comparably aged multi-lender pools but provide a significantly flatter S-curve when in-the-money.
Next, we plot the S-curve for all GNMA RG loans with overlays for loans that are serviced by banks (green) and non-banks (blue). Bank-serviced RG loans prepay significantly slower than non-banks by an average of 9 CPR weighted across all incentives. Further, this difference is caused by voluntary prepays, with buyouts averaging a steady 4% CBR, plus or minus 1 CBR, for both banks and non-banks with no discernable difference between the two (second graph).

Finally, we analyzed the loan-level transition matrix by following each RG loan through its various delinquency states over the past year. We note that the transition rate from Current to 30-day delinquent for RG loans is 1.6%, only marginally worse than that of the entire universe of GNMA loans at 1.1%. RG loans transitioned back from 30->Current at similar rates to the wider Ginnie universe (32.3%) and the 30->60 transition rate for RG loans was marginally worse than the Ginnie universe, 30.8% versus 24.0%.[2]
Monthly Transition Rates for Loans in GNMA RG Pools:
In summary, loans in RG pools have shown a substantial level of voluntary prepayments and comparatively low buyouts, somewhat unexpected especially in light of their recent delinquency. Further, their overall transition rates to higher delinquency states, while greater than the GNMA universe, is markedly better than that of reperforming loans just prior to the outbreak of COVID.
Asset Managers Improving Yields With Resi Whole Loans
An unmistakable transformation is underway among asset managers and insurance companies with respect to whole loan investments. Whereas residential mortgage loan investing has historically been the exclusive province of commercial banks, a growing number of other institutional investors – notably life insurance companies and third-party asset managers – have shifted their attention toward this often-overlooked asset class.
Life companies and other asset managers with primarily long-term, risk-sensitive objectives are no strangers to residential mortgages. Their exposure, however, has traditionally been in the form of mortgage-backed securities, generally taking refuge in the highest-rated bonds. Investors accustomed to the AAA and AA tranches may understandably be leery of whole-loan credit exposure. Infrastructure investments necessary for managing a loan portfolio and the related credit-focused surveillance can also seem burdensome. But a new generation of tech is alleviating more of the burden than ever before and making this less familiar and sometimes misunderstood asset class increasingly accessible to a growing cadre of investors.
Maximizing Yield
Following a period of low interest rates, life companies and other investment managers are increasingly embracing residential whole-loan mortgages as they seek assets with higher returns relative to traditional fixed-income investments (see chart below). As highlighted in the chart below, residential mortgage portfolios, on a loss-adjusted basis, consistently outperform other investments, such as corporate bonds, and look increasingly attractive relative to private-label residential mortgage-backed securities as well.

Nearly one-third of the $12 trillion in U.S. residential mortgage debt outstanding is currently held in the form of loans.
And while most whole loans continue to be held in commercial bank portfolios, a growing number of third-party asset managers have entered the fray as well, often on behalf of their life insurance company clients.

Investing in loans introduces a dimension of credit risk that investors do need to understand and manage through thoughtful surveillance practices. As the chart below (generated using RiskSpan’s Edge Platform) highlights, when evaluating yields on a loss-adjusted basis, resi whole loans routinely generate yield.

In addition to higher yields, whole loans investments offer investors other key advantages over securities. Notably:
Data Transparency
Although transparency into private label RMBS has improved dramatically since the 2008 crisis, nothing compares to the degree of loan-level detail afforded whole-loan investors. Loan investors typically have access to complete loan files and therefore complete loan-level datasets. This allows for running analytics based on virtually any borrower, property, or loan characteristic and contributes to a better risk management environment overall. The deeper analysis enabled by loan-level and property-specific information also permits investors to delve into ESG matters and better assess climate risk.
Daily Servicer Updates
Advancements in investor reporting are increasingly granting whole loan investors access to daily updates on their portfolio performance. Daily updating provides investors near real-time updates on prepayments and curtailments as well as details regarding problem loans that are seriously delinquent or in foreclosure and loss mitigation strategies. Eliminating the various “middlemen” between primary servicers and investors (many of the additional costs of securitization outlined below—master servicers, trustees, various deal and data “agents,” etc.—have the added negative effect of adding layers between security investors and the underlying loans) is one of the things that makes daily updates possible.
Lower Transaction Costs
Driven largely by a lack of trust in the system and lack of transparency into the underlying loan collateral, private-label securities investments incur a series of yield-eroding transactions costs that whole-loan investors can largely avoid. Consider the following transaction costs in a typical securitization:
- Loan Data Agent costs: The concept of a loan data agent is unique to securitization. Data agents function essentially as middlemen responsible for validating the performance of other vendors (such as the Trustee). The fee for this service is avoided entirely by whole loan investors, which generally do not require an intermediary to get regularly updated loan-level data from servicers.
- Securities Administrator/Custodian/Trustee costs: These roles present yet another layer of intermediary costs between the borrower/servicer and securities investors that are not incurred in whole loan investing.
- Deal Agent costs: Deal agents are third party vendors typically charged with enhancing transparency in a mortgage security and ensuring that all parties’ interests are protected. The deal agent typically performs a surveillance role and charges investors ongoing annual fees plus additional fees for individual loan file reviews. These costs are not borne by whole loan investors.
- Due diligence costs: While due diligence costs factor into loan and security investments alike, the additional layers of review required for agency ratings tends to drive these costs higher for securities. While individual file reviews are also required for both types of investments, purchasing loans only from trusted originators allows investors to get comfortable with reviewing a smaller sample of new loans. This can push due diligence costs on loan portfolios to much lower levels when compared to securities.
- Servicing costs: Mortgage servicing costs are largely unavoidable regardless of how the asset is held. Loan investors, however, tend to have more options at their disposal. Servicing fees for securities vary from transaction to transaction with little negotiating power by the security investors. Further, securities investors incur master servicing fees which is generally not a required function for managing whole loan investments.
Emerging technology is streamlining the process of data cleansing, normalization and aggregation, greatly reducing the operational burden of these processes, particularly for whole loan investors, who can cut out many of these intermediary parties entirely.
Overcoming Operational Hurdles
Much of investor reluctance to delve into loans has historically stemmed from the operational challenges (real and perceived) associated with having to manage and make sense of the underlying mountain of loan, borrower, and property data tied to each individual loan. But forward-thinking asset managers are increasingly finding it possible to offload and outsource much of this burden to cloud-native solutions purpose built to store, manage, and provide analytics on loan-level mortgage data, such as RiskSpan’s Edge Platform supporting loan data management and analytics. RiskSpan solutions make it easy to mine available loan portfolios for profitable sub-cohorts, spot risky loans for exclusion, apply a host of credit and prepay scenario analyses, and parse static and performance data in any way imaginable.
At an increasing number of institutions, demonstrating the power of analytical tools and the feasibility of applying them to the operational and risk management challenges at hand will solve many if not most of the hurdles standing in the way of obtaining asset class approval for mortgage loans. The barriers to access are coming down, and the future is brighter than ever for this fascinating, dynamic and profitable asset class.
EDGE: Extension Protection in a Rising Rate Environment
With the Fed starting their tightening cycle and reducing balance sheet, mortgage rates have begun rising. Since late summer, 30-year conforming rates have risen more than 100bp, with 75bp of that occurring since the end of December. The recent flight-to-quality rally has temporarily eased that, but the overall trend remains in place for higher mortgage rates.
With this pivot, mortgage investors have switched from focusing on prepayment protection to mitigating extension risk. In this post, we offer analysis on extension risk and turnover speeds for various out-of-the-money Fannie and Freddie cohorts.[1]
In the chart below, we first focus on out-of-the-money prepays on lower loan balance loans. For this analysis, we analyzed speeds on loans that were 24 to 48 months seasoned. We further grouped the loan balance stories into meta-groups, as the traditional groupings of “85k-Max”, etc, showed little difference in out-of-the-money speeds. When compared to loans with balances above 250k, speeds on lower loan balance loans were a scant 1-2 CPR faster than borrowers with larger loan balances, when prevailing rates were 25bp to 100bp higher than the borrower’s note rate.
We next compare borrowers in low FICO pools, high LTV pools, and 100% investor pools. Speeds on low-FICO pools (blue) offer some extension protection due to higher involuntary speeds. At the other end, loans in 100% investor pools were dramatically slower than non-spec pools when out-of-the money.
Finally, we look at the behavior of borrowers in non-spec pools segregated by loan purpose, again controlling for loan age. Borrowers with refi loans pay significantly faster than purchase loans when only slightly out-of-the money. As rates continue to rise, refi speeds converge to purchase loans at 75bp out of the money and pay slower when 75-100bp out of the money, presumably due to a stronger lock-in effect.
We also separated these non-spec borrowers by originators, grouping the largest banks and non-bank originators together. Out-of-the-money speeds on refi loans were significantly faster for loans originated by non-bank originators (blue and green) versus those originated by banks (red and orange). Speeds on purchase loans were only 1-2 CPR faster for non-banks versus banks and were omitted from this graph for readability.
[1] For investors interested in GNMA analysis, please contact RiskSpan
EDGE: The Fed’s MBS, Distribution and Prepayments
Since the Great Financial Crisis of 2008, the Federal Reserve Bank of New York has been the largest and most influential participant in the mortgage-backed securities market. In the past 14 years, the Fed’s holdings of conventional and GNMA pools has grown from zero to $2.7 trillion, representing roughly a third of the outstanding market. With inflation spiking, the Fed has announced an end to MBS purchases and will shift into balance-sheet-reduction mode. In this short post, we review the Fed’s holdings, their distribution across coupon and vintage, and their potential paydowns as rates rise.
The New York Fed publishes its pool holdings here. The pools are updated weekly and have been loaded into RiskSpan’s Edge Platform. The chart below summarizes the Fed’s 30yr Fannie/Freddie holdings by vintage and net coupon.

We further categorize the Fed’s holdings by vintage and borrower note rate (gross WAC) at the loan level. Using loan-level data (rather than weighted-average statistics published on Fed-held Supers or their constituent pools [1]) provides a more accurate view of the Fed’s distribution of note rates and hence prepayment exposure.

Not surprisingly, the recent and largest quantitative easing has left the Fed holding MBS with gross WACs below the current mortgage rate. Roughly 85% of the mortgages held by the Fed are out-of-the-money, and the remaining in-the-money mortgages are several years seasoned. These older pools are beginning to exhibit burnout, with the sizable refinancing wave over the last two years having limited these moderately seasoned loans mainly to borrowers who are less reactive to savings from refinancing.

With most of the Fed’s portfolio at below-market rates and the remaining MBS moderately burned out, market participants expect the Fed’s MBS runoff to continue to slow. At current rates, we estimate that Fed paydowns will continue to decline and stabilize around $25B per month in the second quarter, just shy of 1% of its current MBS holdings.
With these low levels of paydowns, we anticipate the Fed will need to sell MBS if they want to make any sizable reduction in their balance sheet. Whether the Fed feels compelled to do this, or in what manner sales will occur, is an unsettled question. But paydowns alone will not significantly reduce the Fed’s holdings of MBS over the near term.
[1] FNMA publishes loan-level data for pools securitized in 2013 onward. For Fed holdings that were securitized before 2013, we used FNMA pool data.



