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Improving the Precision of MSR Pricing Using Cloud-Native Loan-Level Analytics (Part I)

Traditional MSR valuation approaches based on rep lines and loan characteristics important only to prepayment models fail to adequately account for the significant impact of credit performance on servicing cash flows – even on Agency loans. Incorporating both credit and prepayment modeling into an MSR valuation regime requires a loan-by-loan approach—rep lines are simply insufficient to capture the necessary level of granularity.

Performing such an analysis while evaluating an MSR portfolio containing hundreds of thousands of loans for potential purchase has historically been viewed as impractical. But thanks to today’s cloud-native technology, loan-level MSR portfolio pricing is not just practical but cost-effective.

Introduction

Mortgage Servicing Rights (MSRs) entitle the asset owner to receive a monthly fee in return for providing billing, collection, collateral management and recovery services with respect to a pool of mortgages on behalf of the beneficial owner(s) of those mortgages. This servicing fee consists primarily of two components based on the current balance of each loan:  a base servicing fee (commonly 25bps of the loan balance) and an excess servicing fee.  The latter is simply the difference between each loan rate and the sum of the pass-through rate of interest and the base servicing.

The value of a portfolio of MSRs is determined by modeling the projected net cash flows to the owner and discounting them to the present using one of two methodologies:

  1. Static or Single-Path Pricing: A single series of net servicing cash flows are generated using current interest and mortgage rates which are discounted to a present value using a discount rate reflecting current market conditions.
  2. Stochastic or Option-Adjusted Spread (OAS) Pricing: Recognizing that interest rates will vary over time, a statistical simulation of interest rates is used to generate many time series (typically 250 to 1,000) of net servicing cash flows.  Each time series of cash flows is discounted at a specified spread over a simulated base curve (generally the LIBOR or Treasury curve) and the resulting present value is averaged across all of the paths.

While these two pricing methodologies have different characteristics and are based on very different conceptual frameworks, they both strongly depend on the analyst’s ability to generate reliable forecasts of net servicing cashflows.  As the focus of this white paper is to discuss the key factors that determine the net cashflows, we are indifferent here as to the ultimate methodology used to convert those cashflows into a present value and for simplicity will look to project a single path of net cash flows.  RiskSpan’s Edge platform supports both static and OAS pricing and RiskSpan’s clients use each and sometimes both to value their mortgage instruments.

Modeling Mortgage Cash Flows

Residential mortgages are complex financial instruments. While they are, at their heart, a fixed income instrument with a face amount and a fixed or a floating rate of interest, the ability of borrowers to voluntarily prepay at any time adds significant complexity.  This prepayment option can be triggered by an economic incentive to refinance into a lower interest rate, by a decision to sell the underlying property or by a change in life circumstances leading the borrower to pay off the mortgage but retain the property.

The borrower also has a non-performance option. Though not usually exercised voluntarily, forbearance options made available to borrowers in response to Covid permitted widespread voluntary exercise of this option without meaningful negative consequences to borrowers. This non-performance option ranges from something as simple as a single late payment up to cessation of payments entirely and forfeiture of the underlying property. Forbearance (a payment deferral on a mortgage loan permitted by the servicer or by regulation, such as the COVID-19 CARES Act) became a major factor in understanding the behavior of mortgage cash flows in 2020.

Should a loan default, ultimate recovery depends on a variety of factors, including the loan-to-value ratio, external credit support such as primary mortgage insurance as well as costs and servicer advances paid from liquidation proceeds.

Both the prepayment and credit performance of mortgage loans are estimated with the use of statistical models which draw their structure and parameters from an extremely large dataset of historical performance.  As these are estimated with reference to backward-looking experience, analysts often adjust the models to reflect their experience adjusted for future expectations.

Investors in GSE-guaranteed mortgage pass-through certificates are exposed to voluntary and, to a far less extent, involuntary (default) prepayments of the underlying mortgages.  If the certificates were purchased at a premium and prepayments exceed expectations, the investor’s yield will be reduced.  Conversely, if the certificates were purchased at a discount and prepayments accelerated, the investor’s yield will increase.  Guaranteed pass-through certificate investors are not exposed to the credit performance of the underlying loans except to the extent that delinquencies may suppress voluntary prepayments. Involuntary prepayments and early buyouts of delinquent loans from MBS pools are analogous to prepayments from a cash flow perspective when it comes to guaranteed Agency securities.

Investors in non-Agency securities and whole loans are exposed to the same prepayment risk as guaranteed pass-through investors are, but they are also exposed to the credit performance of each loan. And MSR investors are exposed to credit risk irrespective of whether the loans they service are guaranteed.

Here is why.

The mortgage servicing fee can be simplistically represented by an interest-only (IO) strip carved off of the interest payments on a mortgage. Net MSR cash flows are obtained by subtracting a fixed servicing cost. Securitized IOs are exposed to the same factors as pass-through certificates, but their sensitivity to those factors is magnitudes greater because a prepayment constitutes the termination of all further cash flows – no principal is received.  Consequently, returns on IO strips are very volatile and sensitive to interest rates via the borrower’s prepayment incentive.

While subtracting fixed costs from the servicing fee is still a common method of generating net MSR cash flows, it is a very imprecise methodology, subject to significant error. The largest component of this error arises from the fact that servicing cost is highly sensitive to the credit state of a mortgage loan. Is the loan current, requiring no intervention on the part of the servicer to obtain payment, or is the loan delinquent, triggering additional, and potentially costly, servicer processes that attempt to restore the loan to current? Is it seriously delinquent, requiring a still higher level of intervention, or in default, necessitating a foreclosure and liquidation effort?

According to the Mortgage Bankers Association, the cost of servicing a non-performing loan ranged from eight to twenty times the cost of servicing a performing loan during the ten-year period from 2009 to 1H2019 (Source: Servicing Operations Study and Forum; PGR 1H2019). Using 2014 as both the mid-point of this ratio and of the time period under consideration, the direct cost of servicing a performing loan was $156, compared to $2,000 for a non-performing loan. Averaged across both performing and non-performing loans, direct servicing costs were $171 per loan, with an additional cost of $31 per loan arising from unreimbursed expenditures related to foreclosure, REO and other costs, plus an estimated $58 per loan of corporate administration expense, totaling $261 per loan.

The average loan balance of FHLMC and FNMA loans in 2014 was approximately $176,000, translating to an annual base servicing fee of $440.

The margins illustrated by these figures demonstrate the extreme sensitivity of net servicing cash flows to the credit performance of the MSR portfolio. After prepayments, credit performance is the most important factor determining the economic return from investing in MSRs.  A 1% increase in non-performing loans from the 10yr average of 3.8% results in a $20 per loan net cash flow decline across the entire portfolio.  Consequently, for servicers who purchase MSR portfolios, careful integration of credit forecasting models into the MSR valuation process, particularly for portfolio acquisitions, is critical.

RiskSpan’s MSR engine integrates both prepayment and credit models, permitting the precise estimation of net cash flows to MSR owners. The primary process affecting the cash inflow to the servicer is prepayment; when a loan prepays, the servicing fee is terminated. The cash outflow side of the equation depends on a number of factors:

  1. First and foremost, direct servicing cost is extremely sensitive to loan performance. The direct cost of servicing rises rapidly as delinquency status becomes increasingly severe. Direct servicing cost of a 30-day delinquent loan varies by servicer but can be as high as 350% of a performing loan. These costs rise to 600% of a performing loan’s cost at 60 days delinquent.
  2. Increasing delinquency causes other costs to escalate, including the cost of principal and interest as well as tax and escrow advances, non-reimbursable collateral protection, foreclosure and liquidation expenses. Float decreases, reducing interest earnings on cash balances.

    Source: Average servicing cost by delinquency state as supplied by several leading servicers of Agency and non-Agency mortgages.


RiskSpan’s MSR platform incorporates the full range of input parameters necessary to fully characterize the positive and negative cash flows arising from servicing. Positive cash flows include the servicing and other fees collected directly from borrowers as well as various types of ancillary and float income. Major contributors to negative cash flows include direct labor costs associated with performing servicing activities as well as unreimbursed foreclosure and liquidation costs, compensating interest and costs associated with financing principal, interest and escrow advances on delinquent loans.

The net cash flows determined at the loan level are aggregated across the entire MSR portfolio and the client’s preferred pricing methodology is applied to calculate a portfolio value.



Aggregation of MSR Portfolio Cash Flows – Loan-by-Loan vs “Rep Lines”

Historically, servicer net cash flows were determined using a simple methodology in which the base servicing fee was reduced by the servicing cost, and forecast prepayments were projected using a prepayment model. The impact of credit performance on net cash flows was explicitly considered by only a minority of practitioners.

Because servicing portfolios can contain hundreds of thousands or millions of loans, the computational challenge of generating net servicing cash flows was quite high. As the industry moved increasingly towards using OAS pricing and risk methodologies to evaluate MSRs, this challenge was multiplied by 250 to 1,000, depending on the number of paths used in the stochastic simulation.

In order to make the computational challenge more tractable, loans in large portfolios have historically been allocated to buckets according to the values of the characteristics of each loan that most explained its performance. In a framework that considered prepayment risk to be the major factor affecting MSR value, the superset of characteristics that mattered were those that were inputs to the prepayment model. This superset was then winnowed down to a handful of characteristics that were considered most explanatory. Each bucket would be converted to a “rep line” that represented the average of the values for each loan that were input into the prepayment models.



Medium-sized servicers historically might have created 500 to 1,500 rep lines to represent their portfolio. Large servicers today may use tens of thousands. 

The core premise supporting the distillation of a large servicing portfolio into a manageable number of rep lines is that each bucket represents a homogenous group of loans that will perform similarly, so that the aggregated net cash flows derived from the rep lines will approximate the performance of the sum of all the individual loans to a desired degree of precision.

The degree of precision obtained from using rep lines was acceptable for valuing going-concern portfolios, particularly if variations in the credit of individual loans and the impact of credit on net cash flows were not explicitly considered.  Over time, movement in MSR portfolio values would be driven mostly by prepayments, which themselves were driven by interest rate volatility. If the modeled value diverged sufficiently from “fair value” or a mark provided by an external provider, a valuation adjustment might be made and reported, but this was almost always a result of actual prepayments deviating from forecast.

Once an analyst looks to incorporate credit performance into MSR valuation, the number of meaningful explanatory loan characteristics grows sharply.  Not only must one consider all the variables that are used to project a mortgage’s cash flows according to its terms (including prepayments), but it also becomes necessary to incorporate all the factors that help one project exercise of the “default option.” Suddenly, the number of loans that could be bucketed together and be considered homogenous with respect to prepayment and credit performance would drop sharply; the number of required buckets would increase dramatically –to the point where the number of rep lines begins to rival the number of loans. The sheer computational power needed for such complex processing has only recently become available to most practitioners and requires a scalable, cloud-native solution to be cost effective.

Two significant developments have forced mortgage servicers to more precisely project net mortgage cash flows:

  1. As the accumulation of MSRs by large market participants through outright purchase, rather than through loan origination, has been growing dramatically, imprecision in valuation became less tolerable as it could result in the servicer bidding too low or too high for a servicing package.
  2. FASB Accounting Standard 2016-13 obligated entities holding “financial assets and net investment in leases that are not accounted for at fair value through net income” to estimate “incurred losses,” or estimated futures losses over the life of the asset. While the Standard does not necessarily apply to MSRs because most MSR investors account for the asset at fair value and flow fair value mark-to-market through income, it did lead to a statement from the major regulators:

“If a financial asset does not share risk characteristics with other financial assets, the new accounting standard requires expected credit losses to be measured on an individual asset basis.” 

(Source: Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, National Credit Union Administration, and Office of the Comptroller of the Currency. “Joint Statement on the New Accounting Standard on Financial Instruments – Credit Losses.” June 17, 2016.).

The result of these developments is that a number of large servicers are revisiting their bucketing methodologies and considering using loan-level analyses to better incorporate the impact of credit on MSR value, particularly when purchasing new packages of MSRs. By enabling MSR investors to re-combine and re-aggregate cash flow results on the fly, loan-level projections open the door to a host of additional, scenario-based analytics. RiskSpan’s cloud-native Edge Platform is uniquely positioned to support these emerging methodologies because it was envisioned and built from the ground up as a loan-level analytical engine. The flexibility afforded by its parallel computing framework allows for complex net-cash-flow calculations on hundreds of thousands of individual mortgage loans simultaneously. The speed and scalability this affords makes the Edge Platform ideally suited for pricing even the largest portfolios of MSR assets and making timely trading decisions with confidence.


In Part II of this series, we will delve into property-level risk characteristics—factors that are not easily rolled up into portfolio rep lines and must be evaluated at the loan level—impact credit risk and servicing cash flows. We will also quantify the impact of a loan-level analysis incorporating these factors on an MSR valuation.

Contact us to learn more.


How Are Ginnie’s New RG Pools Performing?

In February of this year, the Ginnie Mae II program began guaranteeing securities backed by pools of mortgages previously bought out of Ginnie Mae securities because of delinquency. In order to qualify for these new re-performing pools (known as “RG pools”) a loan must meet two (related) conditions: 

  • Borrower has made at least six months of timely payments prior to pool issuance. 
  • Pool issue date is at least 210 days from when the mortgage was last delinquent. 

The novelty of RG pools raises questions about their composition and performance relative to other Ginnie Mae pools. While it remains too early to make many conclusive statements, a preliminary look at the prepayment data indicates speeds somewhere between those of similar vintage Ginnie Mae multi and custom pools, with typical variability from servicer to servicer.  

In this post, we discuss the prepayment behaviors we have observed over the first seven months of RG pool securitization, issuance patterns, and collateral characteristics. 

Prepayments 

Latest September prepayment prints show that RG pools’ speeds generally fell in between those of similar coupon/vintage multi and custom pools.  Below charts shows that 2015/2016 3.5% RG pools prepaid at around 37-38 CPR in September, a couple of CPR slower than similarly aged multi pools and almost 10 CPR faster than custom pools.  


Prepayments for G2 3.5% RG, Custom and Multi Pools by Vintages, September Factor Month Note: Loan level data


Below, we plot S-curves for 49 to 72 wala RG loans against S-curves for similarly aged multi and other custom loans from April to September factor months Speeds for RG loans with 25 to 100 bp of rate incentives have prepaid in mid-30s CPRs (Green line in below figure).  During the same period, similar multi pools have prepaid 5 to 8 CPR faster (blue line) than RG pools while similar custom pools have prepaid around 5 CPR slower (black line) We also overlaid a s-curve for 7 to 18 wala G2 multi pools as a comparison (orange line).


S-curves for RG, Custom and Multi Pools (49 to 72 WALA) April to September Factor Months 
Note: Loan level data, orange line is the s-curve for 7-18 wala G2 multi pools with one-year lookback period 


Not surprisingly, prepayment behavior differs by servicer. Wells-serviced RG pools that are seasoned 49 to 72 months with 25 to 100 bp of rate incentives appear to be prepaying in low 30s CPRs (black line in below figure).  Similar loans from Penny Mac are prepaying 5 to 10 CPR faster, which tends to be the case for non-RG loans as well. 


S-curves for RG loans by servicers, 49 to 72 WALA, April to September Factor MonthsNote: Loan level data 


While the re-performing loans that are being securitized into RG pools are already seasoned loans, prepayments have been increasing as pool seasons.  For example, one-month old RG 3.5% pools have prepaid at 27 CPR while 6- and 7-month 3.5% pools prepaid at 45-50 CPR (black line below). In addition, overall prepayment speeds for same-pool-age 3.0%, 3.5%, and 4.0% have been on top of each other. 


 Prepayments for RG 3.0%, 3.5% and 4.0% Pools by Pool Age, March to September 2021 Note: only showing data points for cohorts with more than 50 loans


Issuance Volume 

Following a brief ramp-up period in February and March, issuance of RG pools has averaged around $2 billion (and roughly 300 pools) per month for the past five months (see Issuance chart below). The outstanding UPB of these pools stands at nearly $11 billion as of the September factor month. 


Note: RiskSpan uses reporting month as a factor month. For this chart, we adjust our factor date by one month to match the collection period.


RG pools already account for a sizable share of Ginnie II custom issuance, as illustrated in the following chart, making up 18% of G2 custom issuance and 3% of all G2 issuance since April.

Note: RiskSpan uses reporting month as a factor month. For this chart, we adjust our factor date by one month to match the collection period. 


RG Pool Characteristics 

Nearly all of RG pool issuance has been in 3.0% to 4.5% coupons, with a plurality at 3.5%. As of the September factor month, almost $4 billion (37%) of the outstanding RG pools are in 3.5% coupons. The 4% coupon accounted for the next-largest share–$2.5 billion (23%)—followed by $2.3 billion in 3.0% (20.9%) and $1.3 billion in 4.5% (11.8%). 


RG Pool Outstanding Amount by Coupon — September Factor Month 


 The following table compares the characteristics of RG pools issued since February with those of G2 single-family custom and multi pools issued during the same period.  The table highlights some interesting differences: 

  • Issuance of RG pools seems to be concentrated in higher coupons (3% to 4%) compared to issuances for G2 custom pools (concentrated on 2.5% and 3.0%) and G2 multi-lender pools (concentrated on 2.0% and 2.5%). 
  • Loan sizes in RG pools tend to fall between those of G2 customs and smaller than G2 multis.  For example, WAOLS for 3.5% RG pools is around 245k and is around 50k smaller than multi pools and 30k larger than other custom pools. 
  • RG pools consist almost exclusively of FHA loans while G2 multis have a much higher share of VA loans.  Almost 98% of 3.5% RG loans are FHA loans. 

 G2 RG vs. G2 Custom and G2 Multi (pools issued since February), Stat as of September Factor Month 

Wells Fargo and Penny Mac are far and away the leaders in RG issuance, accounting collectively for 62% of outstanding RG pools.  


RG Pools by Servicer, September Factor Month 


 How to Run RG Pools in Edge Perspective 

Subscribers to Edge Perspective can run these comparisons (and countless others) themselves using the “GN RG” pool type filter. The “Custom/Multi-lender” filter can likewise be applied to separate those pools in G2SF. 


Contact Us

Contact us if you are interested in seeing variations on this theme. Using Edge, we can examine any loan characteristic and generate an S-curve, aging curve, or time series.


Value Opportunities in Private-Label Investor Loan Deals

The supply of investor loan collateral in private securitizations has surged in 2021 and projects to remain high (more on this below). To gain an informational edge while selecting bonds among this new issuance, traders and investors have asked RiskSpan for data and tools to dissect the performance of investor loans. Below, we first show the performance of investor loans compared to owner-occupied loans, and then offer a glimpse into a few relative value opportunities using our data and analytics platform, Edge.

As background, the increase of investor loan collateral in PLS was spurred by a new FHFA policy, recently suspended, that capped GSE acquisitions of investor and second home loans at 7% of seller volume. This cap forced originators to explore private-label securitization which, while operationally more burdensome than GSE execution, has been more profitable because it bypasses the GSEs’ high loan-level pricing adjustments. Now that this difficult but rewarding PLS path has been more widely traveled, we expect it to become more efficient and to remain popular, even with the GSE channel reopening.

Subsector Performance Comparison: Investor Vs. Owner-Occupied Loans

Investor Loans Promise Longer Collection of Above-Market Rates

Compared to owner-occupants, investors have historically paid above-market mortgage rates for longer periods before refinancing. Figure 1 shows the prepayment rates of investors vs. owner-occupants as a function of refinance incentive (the borrower’s note rate minus the prevailing mortgage rate). As their flatter “s-curve” shows, the rise in investor prepayments as refinance incentive increases is much more subdued than for owner-occupants.

Crucially, this relationship is not fully explained by higher risk-based pricing premiums on investor loans. Figure 2 shows the same comparison as Figure 1 but only for loans with spreads at origination (SATO) between 50 and 75 bps. The categorical difference between owner-occupied and investor prepay speeds is partially reduced but clearly remains. We also tried controlling for property type, but the difference persists. The relative slowness of investors may result from investors spreading their attention across many elements of their P&L besides interest expense, from higher underwriting obstacles for a rental income-driven loan, and/or from lenders limiting allocation of credit to the investor type.

While we plot these graphs over a five-year lookback period to balance desires for recency and sample size, this relationship holds over shorter and longer performance periods as well.


Figure 1: The Investor Loans S-Curve is Significantly Flatter Than the Owner-Occupied Curve
Investor s-curve vs. owner-occupied s-curve. Includes prime credit, no prepayment penalty, original loan size $200K-$400K, ages 6-48 months for the past 5yr period performance.

Source: CoreLogic’s Private-Label RMBS Collateral Dataset, RiskSpan. Note: because the increase in private-label investor loan volume is coming from Agency cutbacks, the historical performance of investor loans within both Agency and private-label datasets are relevant to private-label investor loan future performance. In this analysis we show private-label data because it straightforwardly parses voluntary prepays vs. defaults, which of course is a critical distinction for PL RMBS investors. Nonetheless, where applicable, we have run the analyses in both datasets, each of which corroborates the performance patterns we show.


Figure 2: Even Controlling for SATO, The Investor vs. Owner-Occupied S-Curve Difference Persists

Same as Figure 1 but includes only loans with SATO between 50-75 bps Source: CoreLogic, RiskSpan


Investor Loans Pose Comparable Baseline Risk, Greater Downside Risk to Credit Investors

Credit performance of investor loans has been worse than owner-occupied loans during crises, which justifies a pricing premium. During benign periods, investor loans have defaulted at similar or lower rates than owner-occupied loans – presumably due to more conservative LTVs, FICOs and DTIs among the investor loan type – and have therefore been profitable for credit investors during these periods. See Figure 3.


Figure 3: Investor Loans Have Defaulted at Greater Rates During Crises and Similar Rates in Other Periods vs. Owner-Occupied Loans
Default rates over time, investor loans vs. owner-occupied. Includes prime credit, ages 12-360 months.

Source: CoreLogic, RiskSpan

Relative Value Opportunities Within Investor Loans

California Quicker to Refinance

California has the largest share of U.S. investor mortgages, as it does with all residential mortgages. California borrowers, both investors and owner-occupieds, have exhibited a steeper response to refinance incentives than have borrowers in other states. Figure 4 shows the comparison focusing on investors. While historical home price appreciation has enabled refinances in California, it has done the same in many states. Therefore, the speed differences point to a more active refinance market in California. All else equal, then, RMBS investors will prefer less California collateral.


Figure 4: California Prepays Significantly Faster In the Money
Investor s-curves bucketed by geography (California vs. Other). Includes prime credit, no prepayment penalty, original loan size $200k-$400k, ages 6-48 months for the past 3yr performance period.

Source: CoreLogic, RiskSpan


For AAA Investors, Limited-Doc Investor Loans May Offer a Two-Sided Benefit: They Buoy Premium Bonds, and a Small Sample Suggests They Lift Discount Bonds, Too

Limited-doc investor loans offer senior tranche holders the chance to earn above-market rates for longer than full-doc investor loans, a relative edge for premium bonds (Figure 5). This is intuitive; we would expect limited-doc borrowers to face greater obstacles to refinancing. This difference holds even controlling for spread at origination. Based on a smaller sample, limited-doc investor loans have also turned over more (see greater prepay rates in the negative refinance incentive bucket). This may result from a correlation between limited documentation and more rapid flipping into the rising HPI environment we have had nationally throughout the past seven years. If so, this would mean that limited-doc investor loans also help discount bonds, relative to full-doc investor loans, accelerate repayments at par.

Because limited-doc investor loans are rare in the RMBS 2.0 era, we widened the performance period to the past seven years to get some sample in each of the refinance incentive buckets. Nonetheless, with all the filters we have put on to isolate the effect of documentation type, there are only a few hundred limited-doc investor loans in the negative refinance incentive buckets.


Figure 5: Limited-Doc Investor Loans Have Prepaid Slower In-The-Money and Faster Out-of-the-Money
Investor s-curves bucketed by doc type. Includes prime credit, no prepayment penalty, original loan size $400K-$800K, ages 6-48 months, SATO 25-125bps for the past 7yr performance period.

Source: CoreLogic, RiskSpan


Size Affects Refi Behavior – But Not How You Think

An assumption carried over from Agency performance is that rate-driven prepays get likelier as loan size increases. This pattern holds across conforming loan sizes, but then reverses and refinance response gets flatter again as balances cross $800K. This is true for investor and owner-occupied loans in both Agency and private-label loan data, though of course the number of loans above $800K in the Agency data is small. Figure 6 shows this pattern for private-label investor loans. As shown, in-the-money prepayments are slowest among loans below $200K, as we would expect. But despite their much higher motivation to refinance, loans above $800K have similar S-curves to loans of just $200K-$400K.

The SATO is generally a few basis points higher for these largest loans, but this does not explain away the speed differences. Figure 7 shows the same comparison as Figure 6 except only for loans with SATO between 50-75 bps. Except for a slightly choppier graph because of the reduced sample size, the same rank-ordering is evident. Nor does controlling for property type or geography remove the speed differences. The largest loans, we conclude, have fewer credit alternatives and/or face more stringent underwriting hurdles than smaller loans, hampering their refi rates.

Rate refinances are fastest among the mid-sized loans between $400K-$600K and $600K-$800K. That these last two groups have similar S-curves – despite the greater dollar motivation to refinance for the $600K-$800Kgroup – suggests that the countervailing effect of lower ability to find refinancing outlets is already kicking in for the $600K-$800K size range.

All of this means that high-balance collateral should be more attractive to investors than some traditional prepayment models will appreciate.


Figure 6: The Largest Investor Loans Refinance Slower Than Medium-Sized
Investor s-curves bucketed by loan size. Includes prime credit, no prepayment penalty, ages 6-48 months for the past 5yr performance period.

Source: CoreLogic, RiskSpan


Figure 7: Controlling For SATO, Largest Investor Loans Still Refinance Slower Than Medium-Sized
Same as Figure 4 but includes only loans with SATO between 50-75 bps

Source: CoreLogic, RiskSpan


Preliminarily, Chimera Has Lowest Stressed Delinquencies of Top Investor Shelves

For junior-tranche, credit-exposed investors in the COVID era, 60-day-plus delinquencies have been significantly rarer on Chimera’s shelf than on other top investor shelves. The observable credit mixes of the three shelves appear similar. We ran this analysis with only full-doc loans and from only one state (California), and the rank-ordering of delinquency rates by shelves remains the same. Further to this point, note that the spread at origination of Chimera’s shelf is nearly as high as Flagstar’s. All of this suggests there is something not directly observable about Chimera’s shelf that has generated better credit performance during this stressed period. We caution that differences in servicer reporting of COVID forbearances can distort delinquency data, so we will continue to monitor this performance as our data updates each month.


Figure 8: Chimera Posts Lowest COVID Delinquencies, with Nearly Highest SATO of Top Investor Shelves
Investor DQ60+ rates over time, bucketed by shelf. Includes prime credit, ages 12-60 months.


Source: CoreLogic, RiskSpan


The Greater Default Risk of Low-Doc Investor Loans Lasts About 10 Years

Low-doc investors default more frequently than full-doc investors, but only during the first roughly 120 months of loan age. Around this age, the default rates converge. For loans seasoned beyond this age, full-doc loans begin to default slightly more frequently than low-doc loans, likely due to a survivorship bias. This suggests that credit investors are wise to require a price discount for new issuance with low-doc collateral. For deals with heavily seasoned collateral, junior-tranche investors may counterintuitively prefer low-doc collateral — certainly if they can earn an extra risk premium for it, as it would seem they are not actually bearing any extra credit risk.


Figure 9: Low-Doc Investor Loans Default More Frequently Than Full-Doc Until Loan Age = 120
Investor default rates over time, bucketed by doc type. Includes prime credit, RMBS 2.0 era, for the past 7yr performance period.

Source: CoreLogic, RiskSpan


Summary

  • Investor loans face higher barriers to refinance than owner-occupied, offering RMBS investors the opportunity to earn higher coupons for longer periods.
  • For junior tranche investors, the credit performance of investor loans has been similar to owner-occupied loans during benign economic periods and worse during stressed times.
  • California borrowers respond more quickly to refinance incentives than borrowers from other states; investors will prefer less California collateral.
  • Limited-doc investor loans offer AAA investors a double benefit: slower refinances in the money, extending premium bonds; and faster turnover out of the money, limiting extension risk.
  • Low loan balances are attractive for their slow refinance response – as are non-conforming (high) loan balances above $800K. Traditional prepay models may miss this latter dynamic.
  • For credit investors, Chimera’s delinquency rates have been significantly better during the pandemic than other investor shelves. We will continue to monitor this as different ways of reporting COVID forbearances may confound such comparisons.
  • For credit investors, limited-doc investor loans default at higher rates than full-doc loans for about the first ten years of loan age; after this point the two perform very similarly, with limited-doc loans defaulting at slightly lower rates among these seasoned loans, likely due to survivor biases.

Contact Us

Contact us if you are interested in seeing variations on this theme. Using Edge, we can examine any loan characteristic and generate an S-curve, aging curve, or time series.


An Emerging Climate Risk Consensus for Mortgages?

That climate change poses a growing—and largely unmeasured—risk to housing and mortgage investors is not news. As is often the case with looming threats whose timing and magnitude are only vaguely understood, increased natural hazard risks have most often been discussed anecdotally and in broad generalities. This, however, is beginning to change as the reality of these risks becomes increasingly clear to an increasing number of market participants and industry-sponsored research begins to emerge.

This past week’s special report by the Mortgage Bankers Association’s Research Institute for Housing America, The Impact of Climate Change on Housing and Housing Finance, raises a number of red flags about our industry’s general lack of preparedness and the need for the mortgage industry to take climate risk seriously as a part of a holistic risk management framework. Clearly this cannot happen until appropriate risk scenarios are generated and introduced into credit and prepayment models.

One of the puzzles we are focusing on here at RiskSpan is an approach to creating climate risk stress testing that can be easily incorporated into existing mortgage modeling frameworks—at the loan level—using home price projections and other stress model inputs already in use. We are also partnering with firms who have been developing climate stress scenarios for insurance companies and other related industries to help ensure that the climate risk scenarios we create are consistent with the best and most recently scientific research available.

Also on the short-term horizon is the implementation of FEMA’s new NFIP premiums for Risk Rating 2.0. Phase I of this new framework will begin applying to all new policies issued on or after October 1, 2021. (Phase II kicks in next April.) We wrote about this change back in February when these changes were slated to take effect back in the spring. Political pressure, which delayed the original implementation may also impact the October date, of course. We’ll be keeping a close eye on this and are preparing to help our clients estimate the likely impact of FEMA’s new framework on mortgages (and the properties securing them) in their portfolios.

Finally, this past week’s SEC statement detailing the commission’s expectations for climate-related 10-K disclosures is also garnering significant (and warranted) attention. By reiterating existing guidelines around disclosing material risks and applying them specifically to climate change, the SEC is issuing an unmistakable warning shot at filing companies who fail to take climate risk seriously in their disclosures.

Contact us (or just email me directly if you prefer) to talk about how we are incorporating climate risk scenarios into our in-house credit and prepayment models and how we can help incorporate this into your existing risk management framework.  



Prepayment Spikes in Ida’s Wake – What to Expect

It is, of course, impossible to view the human suffering wrought by Hurricane Ida without being reminded of Hurricane Katrina’s impact 16 years ago. Fortunately, the levees are holding and Ida’s toll appears likely to be less severe. It is nevertheless worth taking a look at what happened to mortgages in the wake of New Orleans’s last major catastrophic weather event as it is reasonable to assume that prepayments could follow a similar pattern (though likely in a more muted way).

Following Katrina, prepayment speeds for pools of mortgages located entirely in Louisiana spiked between November 2005 and June 2006. As the following graph shows, prepayment speeds on Louisiana properties (the black curve) remained elevated relative to properties nationally (the blue curve) until the end of 2006. 

Comparing S-curves of Louisiana loans (the black curve in the chart below) versus all loans (the green curve) during the spike period (Nov. 2005 to Jun. 2006) reveals speeds ranging from 10 to 20 CPR faster across all refinance incentives. The figure below depicts an S-curve for non-spec 100% Louisiana pools and all non-spec pools with a weighted average loan age of 7 to 60 months during the period indicated.

The impact of Katrina on Louisiana prepayments becomes even more apparent when we consider speeds prior to the storm. As the S-curves below show, non-specified 100% Louisiana pools (the black curve) actually paid slightly slower than all non-spec pools between November 2003 and October 2005.

As we pointed out in June, a significant majority of prepayments caused by natural disaster events are likely to be voluntary, as opposed to the result of default as one might expect. This is because mortgages on homes that are fully indemnified against these perils are likely to be prepaid using insurance proceeds. This dynamic is reflected in the charts below, which show elevated voluntary prepayment rates running considerably higher than the delinquency spike in the wake of Katrina. We are able to isolate voluntary prepayment activity by looking at the GSE Loan Level Historical Performance datasets that include detailed credit information. This enables us to confirm that the prepay spike is largely driven by voluntary prepayments. Consequently, recent covid-era policy changes that may reduce the incidence of delinquent loan buyouts from MBS are unlikely to affect the dynamics underlying the prepayment behavior described above.

RiskSpan’s Edge Platform enables users to identify Louisiana-based loans and pools by drilling down into cohort details. The example below returns over $1 billion in Louisiana-only pools and $70 billion in Louisiana loans as of the August 2021 factor month.


Edge also allows users to structure more specified queries to identify the exposure of any portfolio or portfolio subset. Edge, in fact, can be used to examine any loan characteristic to generate S-curves, aging curves, and time series.  Contact us to learn more.



EDGE: QM vs Non-QM Prepayments

Prepayment speeds for qualified mortgages (QM loans) have anecdotally been faster than non-QM loans. For various reasons, the data necessary to analyze interest rate incentive response has not been readily available for these categories of mortgages.

In order to facilitate the generation of traditional refinancing curves (S-curves) over the last year, we have normalized data to improve the differentiation of QM versus non-QM loans within non-agency securities.

Additionally, we isolated the population to remove prepay impact from loan balance and seasoning.

The analysis below was performed on securitized loans with 9 to 36 months of seasoning and an original balance between 200k and 500k. S-curves were generated for observation periods from January 2016 through July 2021.

Results are shown in the table and chart below.

 


 

For this analysis, refinance incentive was calculated as the difference between mortgage note rate and the 6-week lagged Freddie Mac primary mortgage market survey (PMMS) rate. Non-QM borrowers would not be able to easily refi into a conventional mortgage. We further analyzed the data by examining prepayments speeds for QM and non-QM loans at different level of SATO. SATO, the spread at origination, is calculated as the difference between mortgage note rate and the prevailing PMMS rate at time of loan’s origination.

 

Using empirical data maintained by RiskSpan, it can be seen the refinance response for QM loans remains significantly faster than Non-QM loans.

Using Edge, RiskSpan’s data analytics platform, we can examine any loan characteristic and generate S-curves, aging curves, and time series. If you are interested in performing historical analysis on securitized loan data, please contact us for a free demonstration.


Managing Market Risk for Crypto Currencies

 

Contents

 

Overview

Asset Volatility vs Asset Sensitivity to Benchmark (Beta)

Portfolio Asset Covariance

Value at Risk (VaR)

Bitcoin Futures: Basis and Proxies

Intraday Value at Risk (VaR)

Risk-Based Limits

VaR Validation (Bayesian Approach)

Scenario Analysis

Conclusion


Overview

Crypto currencies have now become part of institutional investment strategies. According to CoinShares, assets held under management by crypto managers reached $57B at the end of Q1 2021.  

Like any other financial asset, crypto investments are subject to market risk monitoring with several approaches evolving. Crypto currencies exhibit no obvious correlation to other assets classes, risk factors  or economic variables. However, crypto currencies have exhibited high price volatility and have enough historical data to implement a robust market risk process. 

In this paper we discuss approaches to implementing market risk analytics for a portfolio of crypto assets. We will look at betas to benchmarks, correlations, Value at Risk (VaR) and historical event scenarios. 

Value at Risk allows risk managers to implement risk-based limits structures, instead of relying on traditional notional measures. The methodology we propose enables consolidation of risk for crypto assets with the rest of the portfolio. We will also discuss the use of granular time horizons for intraday limit monitoring. 

Asset Volatility vs Asset Sensitivity to Benchmark (Beta)

For exchange-traded instruments, beta measures the sensitivity of asset price returns relative to a benchmark. For US-listed large cap stocks, beta is generally computed relative to the S&P 500 index. For crypto currencies, several eligible benchmark indices have emerged that represent the performance of the overall crypto currency market.

We analyzed several currencies against S&P’s Bitcoin Index (SPBTC). SPBTC is designed to track the performance of the original crypto asset, Bitcoin. As market capitalization for other currencies grows, it would be more appropriate to switch to a dynamic multi-currency index such as Nasdaq’s NCI. At the time of this paper, Bitcoin constituted 62.4% of NCI.

Traditionally, beta is calculated over a variable time frame using least squares fit on a linear regression of benchmark return and asset return. One of the issues with calculating betas is the variability of the beta itself. In order to overcome that, especially given the volatility of crypto currencies, we recommend using a rolling beta.

Due to the varying levels of volatility and liquidity of various crypto currencies, a regression model may not always be a good fit. In addition to tracking fit through R-squared, it is important to track confidence level for the computed betas.

Figure 1 History of Beta to S&P Bitcoin Index with Confidence Intervals

The chart above shows rolling betas and confidence intervals for four crypto currencies between January 2019 and July 2021. Beta and confidence interval both vary over time and periods of high volatility (stress) cause a larger dislocation in the value of beta.

Rolling betas can be used to generate a hierarchical distribution of expected asset values.

Portfolio Asset Covariance

Beta is a useful measure to track an asset’s volatility relative to a single benchmark. In order to numerically analyze the risk exposure (variance) of a portfolio with multiple crypto assets, we need to compute a covariance matrix. Portfolio risk is a function not only of each asset’s volatility but also of the cross-correlation among them.

Figure 2 Correlations for 11 currencies (calculated using observations from 2021)

The table above shows a correlation matrix across 11 crypto assets, including Bitcoin.

Like betas, correlations among assets change over time. But correlation matrices are more unwieldy to track over time than betas are. For this reason, hierarchical models provide a good, practical framework for time-varying covariance matrices.

Value at Risk (VaR)

The VaR for a position or portfolio can be defined as some threshold Τ (in dollars) where the existing position, when faced with market conditions resembling some given historical period, will have P/L greater than Τ with probability k. Typically, k  is chosen to be 99% or 95%.

To compute this threshold Τ, we need to:

  1. Set a significance percentile k, a market observation period, and holding period n.
  2. Generate a set of future market conditions (scenarios) from today to period n.
  3. Compute a P/L on the position for each scenario

After computing each position’s P/L, we sum the P/L for each scenario and then rank the scenarios’ P/Ls to find the the k th percentile (worst) loss. This loss defines our VaR Τ at the the k th percentile for observation-period length n.

Determining what significance percentile k and observation length n to use is straightforward and often dictated by regulatory rules. For example, 99th percentile 10-day VaR is used for risk-based capital under the Market Risk Rule. Generating the scenarios and computing P/L under these scenarios is open to interpretation. We cover each of these, along with the advantages and drawbacks of each, in the next two sections.

To compute VaR, we first need to generate projective scenarios of market conditions. Broadly speaking, there are two ways to derive this set of scenarios:

  1. Project future market conditions using historical (actual) changes in market conditions
  2. Project future market conditions using a Monte Carlo simulation framework

In this paper, we consider a historical simulation approach.

RiskSpan projects future market conditions using actual (observed) n-period changes in market conditions over the lookback period. For example, if we are computing 1-day VaR for regulatory capital usage under the Market Risk Rule, RiskSpan takes actual daily changes in risk factors. This approach allows our VaR scenarios to account for natural changes in correlation under extreme market moves. RiskSpan finds this to be a more natural way of capturing changing correlations without the arbitrary overlay of how to change correlations in extreme market moves. This, in turn, will more accurately capture VaR. Please note that newer crypto currencies may not have enough data to generate a meaningful set of historical scenarios. In these cases, using a benchmark adjusted by a short-term beta may be used as an alternative.

One key consideration for the historical simulation approach is the selection of the observation window or lookback period. Most regulatory guidelines require at least a one-year window. However, practitioners also recommend a shorter lookback period for highly volatile assets. In the chart below we illustrate how VaR for our portfolio of crypto currencies changes for a range of lookback periods and confidence intervals. Please note that VaR is expressed as a percentage of portfolio market value.

Use of an exponentially weighted moving average methodology can be used to overcome the challenges associated with using a shorter lookback period. This approach emphasizes recent observations by using exponentially weighted moving averages of squared deviations. In contrast to equally weighted approaches, these approaches attach different weights to the past observations contained in the observation period. Because the weights decline exponentially, the most recent observations receive much more weight than earlier observations.

Figure 3 Daily VaR as % of Market Value calculated using various historical observation periods

VaR as a single number does not represent the distribution of P/L outcomes. In addition to computing VaR under various confidence intervals, we also compute expected shortfall, worst loss, and standard deviation of simulated P/L vectors. Worst loss and standard deviation are self-explanatory while the calculation of expected shortfall is described below.

Expected shortfall is the average of all the P/L figures to the left of the VaR figure. If we have 1,000 simulated P/L vectors, and the VaR is the 950th worst case observation, the expected shortfall is the average of P/Ls from 951 to 1000. 

The table below presents VaR-related metrics as a percentage of portfolio market value under various lookback periods.

Figure 4 VaR for a portfolio of crypto assets computed for various lookback periods and confidence intervals

Bitcoin Futures: Basis and Proxies

One of the most popular trades for commodity futures is the basis trade. This is when traders build a strategy around the difference between the spot price and futures contract price of a commodity. This exists in corn, soybean, oil and of course Bitcoin. 

For the purpose of calculating VaR, specific contracts may not provide enough history and risk systems use continuous contracts. Continuous contracts introduce additional basis as seen in the chart below. Risk managers need to work with the front office to align risk factor selection with trading strategies, without compromising independence of the risk process.

Figure 5 BTC/Futures basis difference between generic and active contracts

Intraday Value

The highly volatile nature of crypto currencies requires another consideration for VaR calculations. A typical risk process is run at the end of the day and VaR is calculated for a one-day or longer forecasting period. But Crypto currencies, especially Bitcoin, can also show significant intraday price movements. 

We obtained intraday prices for Bitcoin (BTC) from Gemini, which is ranked third by volume. This data was normalized to create time series to generate historical simulations. The chart below shows VaR as a percentage of market value for Bitcoin (BTC) for one-minute, one-hour and one-day forecasting periods. Our analysis shows that a Bitcoin position can lose as much as 3.5% of its value in one hour (99th percentile VaR).

 

Risk-Based Limits 

Right from the inception of Value at Risk as a concept it has been used by companies to manage limits for a trading unit. VaR serves as a single risk-based limit metric with several advantages and a few challenges:

Pros of using VaR for risk-based limit:

  • VaR can be applied across all levels of portfolio aggregation.
  • Aggregations can be applied across varying exposures and strategies.
  • Today’s cloud scale makes it easy to calculate VaR using granular risk factor data.

VaR can be subject to model risk and manipulation. Transparency and use of market risk factors can avoid this pitfall.

Ability to calculate intra-day VaR is key for a risk-based limit implementation for crypto assets. Risk managers should consider at least an hourly VaR limit in addition to the traditional daily limits.

VaR Validation (Bayesian Approach)

Standard approaches for back-testing VaR are applicable to portfolios of crypto assets as well.

Given the volatile nature of this asset class, we also explored an approach to validating the confidence interval and percentiles implied from historical simulations. Although this is a topic that deserves its own document, we present a high-level explanation and results of our analysis.

Building an approach first proposed in the Pyfolio library, we generated a posterior distribution using the Pymc3 package from our historically observed VaR simulations.

Sampling routines from Pymc3 were used to generate 10,000 simulations of the 3-year lookback case. A distribution of percentiles (VaR) was then computed across these simulations.

The distribution shows that the mean 95th percentile VaR would be 7.3% vs 8.9% calculated using the historical simulation approach. However, the tail of the distribution indicates a VaR closer to the historical simulation approach. One could conclude that the test indicates that the original calculation still represents the extreme case, which is the motivation behind VaR.

Figure 6 Distribution of percentiles generated from posterior simulations

Scenario Analysis

In addition to standard shock scenarios, we recommend using the volatility of Bitcoin to construct a simulation of outcomes. The chart below shows the change in Bitcoin (BTC) volatility for select events in the last two years. Outside of standard macro events, crypto assets respond to cyber security events and media effects, including social media.

Figure 7 Weekly observed volatility for Bitcoin  

Conclusion

Given the volatility of crypto assets, we recommend, to the extent possible, a probability distribution approach. At the very least, risk managers should monitor changes in relationship (beta) of assets.

For most financial institutions, crypto assets are part of portfolios that include other traditional asset classes. A standard approach must be used across all asset classes, which may make it challenging to apply shorter lookback windows for computing VaR. Use of the exponentially weighted moving approach (described above) may be considered.

Intraday VaR for this asset class can be significant and risk managers should set appropriate limits to manage downward risk.

Idiosyncratic risks associated with this asset class have created a need for monitoring scenarios not necessarily applicable to other asset classes. For this reason, more scenarios pertaining to cyber risk are beginning to be applied across other asset classes.  

CONTACT US TO LEARN MORE!

Related Article

Calculating VaR: A Review of Methods


RiskSpan Named to Inaugural STORM50 Ranking by Chartis Research – Winner of “A.I. Innovation in Capital Markets”

Chartis Research has named RiskSpan to its Inaugural “STORM50” Ranking of leading risk and analytics providers. The STORM report “focuses on the computational infrastructure and algorithmic efficiency of the vast array of technology tools used across the financial services industry” and identifies industry-leading vendors that excel in the delivery of Statistical Techniques, Optimization frameworks, and Risk Models of all types. 

RiskSpan’s flagship Edge Platform was a natural fit for the designation because of its positioning squarely at the nexus of statistical behavioral modeling (specifically around mortgage credit and prepayment risk) and functionality enabling users to optimize trading and asset management strategies.  Being named the winner of the “A.I. Innovation in Capital Markets” solutions category reflects the work of RiskSpan’s vibrant innovation lab, which includes researching and developing machine learning solutions to structured finance challenges. These solutions include mining a growing trove of alternative/unstructured data sources, anomaly detection in loan-level and other datasets, and natural language processing for constructing deal cash flow models from legal documents.

Learn more about the Edge Platform or contact us to discuss ways we might help you modernize and improve your mortgage and structured finance data and analytics challenges. 


Is the housing market overheated? It depends where you are.

Mortgage credit risk modeling has evolved slowly in the last few decades. While enhancements leveraging conventional and alternative data have improved underwriter insights into borrower income and assets, advances in data supporting underlying property valuations have been slow. With loan-to-value ratios being such a key driver of loan performance, the stability of a subject property’s value is arguably as important as the stability of a borrower’s income.

Most investors rely on current transaction prices to value comparable properties, largely ignoring the risks to the sustainability of those prices. Lacking the data necessary to identify crucial factors related to a property value’s long-term sustainability, investors generally have little choice but to rely on current snapshots. To address this problem, credit modelers at RiskSpan are embarking on an analytics journey to evaluate the long-term sustainability of a property’s value.

To this end, we are working to pull together a deep dataset of factors related to long-term home price resiliency. We plan to distill these factors into a framework that will enable homebuyers, underwriters, and investors to quickly assess the risk inherent to the property’s physical location. The data we are collecting falls into three broad categories:

  • Regional Economic Trends
  • Climate and Natural Hazard Risk
  • Community Factors

Although regional home price outlook sometimes factors into mortgage underwriting, the long-term sustainability of an individual home price is seldom, if ever, taken into account. The future value of a secured property is arguably of greater importance to mortgage investors than its value at origination. Shouldn’t they be taking an interest in regional economic condition, exposure to climate risk, and other contributors to a property valuation’s stability?

We plan to introduce analytics across all three of these dimensions in the coming months. We are particularly excited about the approach we’re developing to analyze climate and natural hazard risk. We will kick things off, however, with basic economic factors. We are tracking the long-term sustainability of house prices through time by tracking economic fundamentals at the regional level, starting with the ratio of home prices to median household income.

Economic Factors

Housing is hot. Home prices jumped 12.7% nationally in 2020, according to FHFA’s house price index[1]. Few economists are worried about a new housing bubble, and most attribute this rise to supply and demand dynamics. Housing supply is low and rising housing demand is a function of demography –millennials are hitting 40 and want a home of their own.

But even if the current dynamic is largely driven by low supply, there comes a certain point at which house prices deviate too much from area median household income to be sustainable. Those who bear the most significant exposure to mortgage credit risk, such as GSEs and mortgage insurers, track regional house price dynamics to monitor regions that might be pulling away from fundamentals.

Regional home-price-to-income ratio is a tried-and-true metric for judging whether a regional market is overheating or under-valued. We have scored each MSA by comparing its current home-price-to-income ratio to its long-term average. As the chart below illustrating this ratio’s trend shows, certain MSAs, such as New York, consistently have higher ratios than other, more affordable MSAs, such as Chicago.

Because comparing one MSA to another in this context is not particularly revealing, we instead compare each MSA’s current ratio to the long-term ratio for itself. MSAs where that ratio exceeds its long-term average are potentially over-heated, while MSAs under that ratio potentially have more room to grow. In the table below highlighting the top 25 MSAs based on population, we look at how the home-price-to-household-income ratio deviates from its MSA long-term average. The metric currently suggests that Dallas, Denver, Phoenix, and Portland are experiencing potential market dislocation.

Loans originated during periods of over-heating have a higher probability of default, as illustrated in the scatterplot below. This plot shows the correlation between the extent of the house-price-to-income ratio’s deviation from its long-term average and mortgage default rates. Each dot represents all loan originations in a given MSA for a given year[1]. Only regions with large deviations in house price to income ratio saw explosive default rates during the housing crisis. This metric can be a valuable tool for loan and SFR investors to flag metros to be wary of (or conversely, which metros might be a good buy).

Although admittedly a simple view of regional economic dynamics driving house prices (fundamentals such as employment, housing starts per capita, and population trends also play important roles) median income is an appropriate place to start. Median income has historically proven itself a valuable tool for spotting regional price dislocations and we expect it will continue to be. Watch this space as we continue to add these and other elements to further refine how we measure property value stability and its likely impact on mortgage credit.


[1] FHFA Purchase Only USA NSA % Change over last 4 quarters

Contact us to learn more.



Is Your Enterprise Risk Management Keeping Up with Recent Regulatory Changes?​

For enterprise risk managers, ensuring that all the firm’s various risk management structures and frameworks are keeping up with ever-changing regulatory guidance can be a daunting task. Regulatory updates take on particular importance for model risk managers. MRM is required not only to understand and comply with the regulatory guidance specific to model risk management itself, but also to understand the regulatory ramifications of the risk models they validate.

This post focuses on recent updates to eight ERM areas that can sometimes seem like a moving target when it comes to risk compliance.

The timeline below illustrates the extensive variability that can exist from regulator to regulator when it comes to which ERM components are of most concern and the nature and speed of adoption. To take one example, model risk management guidance was issued in 2011 and all Fed- and OCC-regulated institutions were in general compliance with it by 2014. The FDIC, however, did not issue the same guidance until 2017 and enforcement varies considerably. Although every FDIC-regulated institution is technically required to be in compliance with the MRM guidance, several have yet to undergo even their first MRM exam. Things get even cloudier for credit unions as the NCUA has not issued any guidance or regulation pertaining to MRM. The NCUA requires MRM practices to be observed during Capital Planning and Stress Testing (per its 2019 capital planning guide). But this narrow definition allows most credit unions to skirt regulator-required MRM entirely.

Because it can be difficult to stay on top of which regulator is requiring what and when, here is a quick summary of recent updates, organized by risk area.

Bank Secrecy Act (BSA/ Anti Money Laundering (AML) 

The past year has seen five guidance updates pertaining to BSA/AML. Most of these seek to increase the effectiveness, predictability, and transparency of BSA/AML regulatory exams. Other updates clarify specific aspects of BSA/AML risk.

  1. Updated Sections of the FFIEC BSA/AML Examination Manual (OCC 2021-10/SR 21-9 & OCC 2021-28). The updated sections:
    • Reinforce the risk-focused approach to BSA/AML examinations, and
    • Clarify regulatory requirements and include updated information for examiners regarding transaction testing, including examples.
  1. Interagency Statement on Model Risk Management for Bank Systems Supporting BSA/AML Compliance and Request for Information (OCC 2021-19/SR 21-8) as of April 12, 2021. This guidance:
    • Outlines the importance of MRM governance to AML exams,
    • Is designed to be flexible when applying MRM principals to BSA/AML models,
    • Updates MRM principles and validation to be more responsive,
    • Seeks not to apply a single industry-wide approach, and
    • Directs validators to consider third-party documentation when reviewing AML models.
  1. Answers to Frequently Asked Questions Regarding Suspicious Activity Reporting and Other AML Considerations (OCC 2021-4) as of January 21, 2021. These include instructions around:
    • Requests by law enforcement for financial institutions to maintain accounts,
    • Receipt of grand jury subpoenas/law enforcement inquiries and suspicious activity report (SAR) filing,
    • Maintaining a customer relationship following the filing of a SAR or multiple SARs,
    • SAR filing on negative news identified in media searches,
    • SAR monitoring on multiple negative media alerts,
    • Information in data fields and narrative, and
    • SAR character limits.
  1. Joint Statement on Bank Secrecy Act Due Diligence Requirements for Customers Who May Be Considered Politically Exposed Persons (OCC 2020-77/SR 20-19) as of August 21, 2020. This statement:
    • Explains that the BSA/AML regulations do not define what constitutes a politically exposed person (PEP),
    • Clarifies that the customer due diligence rule does not create a regulatory requirement and that there is no supervisory expectation for banks to have unique, additional due diligence steps for PEPs,
    • Clarifies how banks can apply a risk-based approach to customer due diligence in developing risk profiles for their customers, and
    • Discusses potential risk factors, levels and types of due diligence.
  1. OCC-Proposed Rule Regarding Exemptions to Suspicious Activity Report Requirements as of December 17, 2020:
    • The proposed rule would amend the agency’s SAR regulations to allow the OCC to issue exemptions from the requirements of those regulations on when and how to file suspicious activity reports (SARs).
Allowance for Loan and Lease Losses (ALLL)/ Current Expected Credit Losses (CECL) 

Current Expected Credit Losses: Final Rule (OCC 2020-85/SR 19-8/FIL-7-2021) as of October 1, 2020. The rule:

    • Applies to all community banks that adopted CECL in 2020 per GAAP requirements,
    • Exempts all other institutions until 2023,
    • Adopts all of the 2020 CECL IFR, and
    • Clarifies that a banking organization is not required to use the transition during fiscal quarters in which it would not generate a regulatory capital benefit.
Asset Liability Management (ALM) and Liquidity Risk Management 

Four important updates to ALM and liquidity risk guidance were issued in the past year.

  1. Net Stable Funding Ratio: Final Rule (OCC 2021-9) as of February 24, 2021. The rule:
    • Implements a minimum stable funding requirement designed to reduce the likelihood that disruptions to a covered company’s regular sources of funding will compromise its liquidity position,
    • Requires the maintenance a ratio of “available stable funding” to “required stable funding” of at least 1.0 on an ongoing basis,
    • Defines “available stable funding” as the stability of a banking organization’s funding sources,
    • Defines “required stable funding” as the liquidity characteristics of a banking organization’s assets, derivatives, and off-balance-sheet exposures,
    • Requires notification of a shortfall, realized or potential within 10 business days, and
    • Provides public disclosure rules for a consolidated NSFR.
  1. Volcker Rule Covered Funds: Final Rule (OCC 2020-71) as of July 41, 2020. The rule:
    • Permits the activities of qualifying foreign excluded funds,
    • Revises the exclusions from the definition of “covered fund,”
    • Creates new exclusions from the definition of covered fund for credit funds, qualifying venture capital funds, family wealth management vehicles, and customer facilitation vehicles, and
    • Modifies the definition of “ownership interest.”
  1. Interest Rate Risk: Revised Comptroller’s Handbook Booklet (OCC 2020-26) as of March 26, 2020. The updated Handbook:
    • Expands discussions on MRM expectations for reviewing and testing model assumptions,
    • Addresses funds transfer pricing (FTP), and
    • Adds guidelines for advanced approaches to interest rate risk management consistent with the Pillar 2 supervisory approach.
  1. Capital and Liquidity Treatment for Money Market Liquidity Facility and Paycheck Protection Program: Final Rule (OCC 2020-96) as of November 3, 2020. This rule:
    • Permits a zero-percent risk weight for PPP loans,
    • Eliminates the regulatory capital impact and liquidity rule provisions for participating in the PPP and Money Market Liquidity Facility.
Artificial Intelligence (AL)/ Machine Learning (ML) 

The only recent regulatory update pertaining to AI/Machine Learning has been a request for comment related to usage, controls, governance, and risk. At present, there is no formal guidance specifically related to AI or ML models. The OCC’s semi-annual risk perspectives includes just a couple of sentences stating that users of ML models should be able to defend and explain their risks. The Fed’s feedback has been similarly broad. Movement seems afoot to issue more detailed guidance on how ML models should be governed and monitored. But this is likely to be limited to specific applications and not to the ML models themselves.

The Request for Information and Comment on Financial Institutions’ Use of Artificial Intelligence, Including Machine Learning (OCC 2021-17) as of March 31, 2021, seeks respondents’ views on appropriate governance, risk management, and controls over artificial intelligence, and any challenges in developing, adopting, and managing artificial intelligence approaches.

Capital Risk 

We focus on the two items of capital risk guidance issued in the past year. The rule applies to community banks with total assets of less than $10 billion as of December 31, 2019.

  1. Temporary Asset Thresholds: Interim Final Rule (OCC 2020-107) as of December 2, 2020:
    • The rule allows these institutions to use asset data as of December 31, 2019, to determine the applicability of various regulatory asset thresholds during calendar years 2020 and 2021.
  1. Regulatory Capital Rule: Eligible Retained Income: Final Rule (OCC 2020-87) as of October 8, 2020:

The final rule revises the definition of eligible retained income to the greater of:

    • Net income for the four preceding calendar quarters, net of any distributions and associated tax effects not already reflected in net income, and
    • The average of a Bank’s net income over the preceding four quarters.
Fair Lending 
  1. Community Reinvestment Act: Key Provisions of the June 2020 CRA Rule and Frequently Asked Questions (OCC 2020-99) as of November 9, 2020:

The rule establishes new criteria for designating bank assessment areas, including:

    • Facility-based assessment areas based on the location of a bank’s main office and branches and, at a bank’s discretion, on the location of the bank’s deposit-taking automated teller machines, and
    • Deposit-based assessment areas, which apply to a bank with 50 percent or more of its retail domestic deposits outside its facility-based assessment areas.
  1. Community Reinvestment Act: Implementation of the June 2020 Final Rule (OCC 2021-24) as of May 18, 2021. The OCC has determined that it will reconsider its June 2020 rule. While this reconsideration is ongoing, the OCC will not implement or rely on the evaluation criteria in the June 2020 rule pertaining to:
    • Quantification of qualifying activities
    • Assessment areas
    • General performance standards
    • Data collection
    • Recordkeeping
    • Reporting
Market Risk 
  1. Libor Transition: Self-Assessment Tool for Banks (OCC 2021-7) as of February 10, 2021. The self-assessment tool can be used to assess the following:
    • Five primary topics: Assets and contracts; LIBOR risk exposure; Fallback language; Consumer impact; Third-party service provider
    • The appropriateness of a bank’s Libor transition plan
    • Bank management’s execution of the bank’s transition plan
    • Related oversight and reporting
  1. Standardized Approach for Counterparty Credit Risk; Correction: Final Rule (OCC 2020-82) as of September 21, 2020. The issuance corrects errors in the standardized approach for counterparty credit risk (SA-CCR) rule:
    • Clarifying that a Bank that uses SA-CCR will be permitted to exclude the future exposure of all credit derivatives
    • Revising the number of outstanding margin disputes
    • Correcting the calculation of the hypothetical capital requirement of a qualifying central counterparty (QCCP)
  1. Agencies Finalize Amendments to Swap Margin Rule (News Release 2020-83) as of June 25, 2020:
    • Swap entities that are part of the same banking organization will no longer be required to hold a specific amount of initial margin for uncleared swaps with each other, known as inter-affiliate swaps.
    • Final rule allows swap entities to amend legacy swaps to replace the reference to LIBOR or other reference rates that are expected to end without triggering margin exchange requirements.
Operations Risk
  1. Corporate and Risk Governance. Revised and New Publications in the Director’s Toolkit (OCC 2020-97) as of November 5, 2020:
    • Defines permissible derivatives activities,
    • Allows engagement in certain tax equity finance transactions,
    • Expands the ability to choose corporate governance provisions under state law,
    • Includes OCC interpretations relating to capital stock issuances and repurchases, and
    • Applies rules relating to finder activities, indemnification, equity kickers, postal services, independent undertakings, and hours and closings to FSAs.
  1. Activities and Operations of National Banks and Federal Savings Associations: Final Rule (OCC 2020-111) as of December 23, 2020:
    • Focuses on key areas of planning, operations, and risk management,
    • Outlines directors’ responsibilities as well as management’s role,
    • Explains basic concepts and standards for safe and sound operation of banks, and
    • Delineates laws and regulations that apply to banks.
  1. Operational Risk: Sound Practices to Strengthen Operational Resilience (OCC 2020-94) as of October 10, 2020:
    • Outlines standards for operational resilience set forth in the agencies’ rules and guidance,
    • Promotes a principles-based approach for effective governance, robust scenario analysis, secure and resilient information systems, and thorough surveillance and reporting,
    • Introduces sound practices for managing cyber risk.
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