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Articles Tagged with: Mortgage and Structured Finance Markets

Fed MBS Runoff Portends More Negative Vega for the Broader Market

With much anticipation and fanfare, the Federal Reserve is finally on track to reduce its MBS holdings. Guidance from the September FOMC meeting reveals that the Fed will allow its MBS holdings to “run off,” reducing its position via prepayments as opposed to selling it off. What does this Fed MBS Runoff mean for the market? In the long-term, it means a large increase in net supply of Agency MBS and with it an increase in overall implied and realized volatility.

MBS: The Largest Net Source of Options in the Fixed-Income Market

We start this analysis with some basic background on the U.S. MBS market. U.S. homeowners, by in large, finance home purchases using fixed-rate 30-year mortgages. These fixed-rate mortgages amortize over time, allowing the homeowner to pay principal and interest in even, monthly payments. A homeowner has the option to pay off this mortgage early for any reason, which they tend to do when either the homeowner moves, often referred to as turnover, or when prevailing mortgage rates drop significantly below the homeowner’s current mortgage rate, referred to as refinancing or “refis.” As a rough rule-of-thumb, turnover has varied between 6% and 10% per annum as economic conditions vary, whereas refis can drive prepayments to 40% per annum under current lending conditions.[1] Rate refis account for most of a mortgage’s cash flow volatility. If the homeowner is long the option to refinance, the MBS holder is short that same option. Fixed-rate MBS shorten due to prepayments as rates drop, and extend as rates rise, putting the MBS holder into a short convexity (gamma) and short vega position. Some MBS holders hedge this risk explicitly, buying short- and longer-dated options to cover their short gamma/short vega risk. Others hedge dynamically, including money managers and long-only funds that tend to target a duration bogey. One way or another, the short-volatility risk from MBS is transmitted into the larger fixed-income market. Hence, the rates market is net short vol risk. While not all investors hedge their short-volatility position, the aggregate market tends to hedge a similar amount of the short-options position over time. Until, of course, the Fed, the largest buyer of MBS, entered the market. From the start of Quantitative Easing, the Fed purchased progressively more of the MBS market, until by the end of 2014 the Fed just under 30% of the agency MBS market. Over the course of five years, the effective size of the MBS market ex-Fed shrunk by more than a quarter. Since the Fed doesn’t hedge its position, either explicitly through options or implicitly through delta-hedging, the size of the market’s net-short volatility position dropped by a similar fraction.[2]

The Fed’s Balance Sheet

As of early October 2017, the Federal Reserve owned $1.77 trillion agency MBS, or just under 30% of the outstanding agency MBS market. The Fed publishes its holdings weekly which can be found on the New York Fed’s web site here. In the chart below, we summarize the Fed’s 30yr MBS holdings, which make up roughly 90% of the Fed’s MBS holdings. [3]

Fed Holdings - 30yr MBS

Runoff from the Fed

Following its September meeting, the Fed announced they will reduce their balance sheet by not reinvesting run-off from their treasury and MBS portfolio. If the Fed sticks to its plan, MBS monthly runoff from MBS will reach $20B by 2018 Q1. Assuming no growth in the aggregate mortgage market, runoff from these MBS will be replaced with the same size of new, at-the-money MBS passthroughs. Since the Fed is not reinvesting paydowns, these new passthroughs will re-enter the non-Fed-held MBS market, which does hedge volatility by either buying options or delta-hedging. Given the expected runoff rate of the Fed’s portfolio, we can now estimate the vega exposure of new mortgages entering the wider (non-Fed-held) market. When fully implemented, we estimate that $20B in new MBS represents roughly $34 million in vega hitting the market each month. To put that in perspective, that is roughly equivalent to $23 billion notional 3yr->5yr ATM swaption straddles hitting the market each and every month.

Conclusion

While the Fed isn’t selling its MBS holdings, portfolio runoff will have a significant impact on rate volatility. Runoff implies significant net issuance ex-Fed. It’s reasonable to expect increased demand for options hedging, as well as increased delta-hedging, which should drive both implied and realized vol higher over time. This change will manifest itself slowly as monthly prepayments shrinks the Fed’s position. But the reintroduction of negative vega into the wider market represents a change in paradigm which may lead to a more volatile rates market over time.


[1] In the early 2000s, prepayments hit their all-time highs with the aggregate market prepaying in excess of 60% per annum. [2] This is not entirely accurate. The short-vol position in a mortgage passthrough is also a function of its note rate (GWAC) with respect to the prevailing market rate, and the mortgage market has a distribution of note rates. But the statement is broadly true. [3] The remaining Fed holdings are primarily 15yr MBS pass-throughs.


The Non-Agency MBS Market: Re-Assessing Securitization Market Conditions

Since the financial crisis began in 2007, the “Non-Agency” MBS market, i.e., securities neither issued nor guaranteed by Fannie Mae, Freddie Mac, or Ginnie Mae, has been sporadic and has not rebounded from pre-crisis levels. In recent months, however, activity by large financial institutions, such as AIG and Wells Fargo, has indicated a return to the issuance of Non-Agency MBS. What is contributing to the current state of the securitization market for high-quality mortgage loans? Does the recent, limited-scale return to issuance by these institutions signal an increase in private securitization activity in this sector of the securitization market? If so, what is sparking this renewed interest?

 

The MBS Securitization Market

Three entities – Ginnie Mae, Fannie Mae, and Freddie Mac – have been the dominant engine behind mortgage-backed securities (MBS) issuance since 2007. These entities, two of which remain in federal government conservatorship and the third a federal government corporation, have maintained the flow of capital from investors into guaranteed MBS and ensured that mortgage originators have adequate funds to originate certain types of single-family mortgage loans.

Virtually all mortgage loans backed by federal government insurance or guaranty programs, such as those offered by the Federal Housing Administration and the Department of Veterans Affairs, are issued in Ginnie Mae pools. Mortgage loans that are not eligible for these programs are referred to as “Conventional” mortgage loans. In the current market environment, most Conventional mortgage loans are sold to Fannie Mae and Freddie Mac (i.e. “Conforming” loans) and are securitized in Agency-guaranteed pass-through securities.

 

The Non-Agency MBS Market

Not all Conventional mortgage loans are eligible for purchase by Fannie Mae or Freddie Mac, however, due to collateral restrictions (i.e., their loan balances are too high or they do not meet certain underwriting requirements). These are referred to as “Non-Conforming” loans and, for most of the past decade, have been held in portfolio at large financial institutions, rather than placed in private, Non-Agency MBS. The Non-Agency MBS market is further divided into sectors for “Qualified Mortgage” (QM) loans, non-QM loans, re-performing loans and nonperforming loans. This post deals with the securitization of QM loans through Non-Agency MBS programs.

Since the crisis, Non-Agency MBS issuance has been the exclusive province of JP Morgan and Redwood Trust, both of which continue to issue a relatively small number of deals each year. The recent entry of AIG into the Non-Agency MBS market and, combined with Wells Fargo’s announcement that it intends to begin issuing as well, makes this a good time to discuss reasons why these institutions with other funding sources available to them are now moving back to this securitization market sector.

 

Considerations for Issuing QM Loans

Three potential considerations may lead financial institutions to investigate issuing QM Loans through Non-Agency MBS transactions:

  • “All-In” Economics
  • Portfolio Concentration or Limitations
  • Regulatory Pressures

Investigate “All-In” Economics

Over the long-term, mortgage originators gravitate to funding sources that provide the lowest cost to borrowers and profitability for their firms.  To improve the “all-in” economics of a Non-Agency MBS transaction, investment banks work closely with issuers to broaden the investor base for each level of the securitization capital structure.  Partly due to the success of the Fannie Mae and Freddie Mac Credit Risk Transfer transactions, there appears to be significant interest in higher-yielding mortgage-related securities at the lower-rated (i.e. higher risk) end of the securitization capital structure. This need for higher yielding assets has also increased demand for lower-rated securities in the Non-Agency MBS sector.

However, demand from investors at the higher-rated end of the securitization capital structure (i.e. ‘AAA’ and ‘AA’ securities) has not resulted in “all-in” economics for a Non-Agency MBS transaction that surpass the economics of balance sheet financing provided by portfolios funded with low deposit rates or low debt costs. If deposit rates and debt costs remain at historically low levels, the portfolio funding alternative will remain attractive. Notwithstanding the low interest rate environment, some institutions may develop operational capabilities for Non-Agency MBS programs as a risk mitigation process for future periods where balance sheet financing alternatives may not be as beneficial.

 

Portfolio Concentration or Limitations

Due to the lack of robust investor demand and unfavorable economics in Non-Agency MBS, many banks have increased their portfolio exposure to both fixed-rate and intermediate-adjustable-rate QM loans. The ability to hold these mortgage loans in portfolio has provided attractive pricing to a key customer demographic and earned an attractive net interest rate margin during the historical low-rate environment. While bank portfolios have provided an attractive funding source for Non-Agency QM loans, some financial institutions may attempt to develop diversified funding sources in response to regulatory pressure or self-imposed portfolio concentration limits. Selling existing mortgage portfolio assets into the Non-Agency MBS securitization market is one way in which financial institutions might choose to reduce concentrated mortgage risk exposure.

 

Regulatory Pressure

Some financial institutions may be under pressure from their regulators to demonstrate their ability to sell assets out of their mortgage portfolio as a contingency plan. The Non-Agency MBS market is one way of complying with these sorts of regulatory requests. Developing a contingency ability to tap Non-Agency MBS markets develops operational capabilities under less critical circumstances, while assessing the time needed by the institution to liquidate such assets through securitization. This early establishment of securitization functionalities is a prudent activity for those institutions who foresee the possibility of securitization as a future funding option.

While the Non-Agency MBS market has been dormant for most of the past decade, some financial institutions that have relied upon portfolio funding now appear to be testing the current viability of the Non-Agency MBS market. Other mortgage originators would be wise to take notice of these events, monitor activity in these markets, and assess the viability of this alternative funding source for their on-Conforming QM Loans. With the continued issuance by JP Morgan and Redwood Trust and new entrants such as AIG and Wells Fargo, -Non-Agency MBS market activity should be monitored by other mortgage originators to determine whether securitization has the potential to provide an alternative funding source for future lending activity.

In our next article on the Non-Agency MBS market, we will review the changes in due diligence practices, loan-level data disclosures, the representation and warranty framework, and the ratings process made by securitization market participants and the impact of these changes on the Non-Agency MBS market segment.


The Real Reason Low Down Payment VA loans Don’t Default Like Comparable FHA Loans

On this Veterans Day, I was reminded of the Urban Institute’s 2014 article on VA loan performance and its explanation of why VA loans outperform FHA loans.1 The article illustrated how VA loans outperformed comparable FHA loans despite controlling for key variables like FICO, income, and DTI. The article further explained the structural differences and similarities between the veterans program and FHA loans—similarities that include owner occupancy, loan size, and low down payments.

The analysis was well thought out and clearly showed how VA loans outperformed FHA. The article took great care to understand how FICOs, DTI, and income levels could impact default performance. The article further demonstrated VA outperformance wasn’t a recent or short-lived trend.

Its concluding rationale for superior performance was based on:

  1. VA’s residual income test
  2. VA’s loss mitigation efforts
  3. Lender’s “skin in the game”
  4. Lender concentration
  5. Military culture

Two of these reasons assume VA’s internal policies made the difference. Two of the reasons assume lenders’ ability to self-regulate credit policy or capital had an influence. The final reason centered on veterans as a social group with differing values that contributed to the difference.

As someone who has spent his mortgage career between modeling credit, counterparty risks and managing credit underwriters, the lack of good analytical data or anecdotal evidence makes it hard to see how these reasons can account for VA’s strong relative default performance versus FHA. While I understand their rationale, I don’t see how it makes for a compelling explanation.

VA Internal Policies

The residual income test is a tertiary measure used by lenders to qualify borrowers. It is used after applying the traditional MTI (mortgage payment to income) and DTI (total debt to income) ratios. The test mandates that the borrowing veteran have a minimum net income after paying all mortgage and debt payments. But as a third-level underwriting test, it is hard to see how it could be the source of so much of default performance improvement.

The same goes for VA’s loss mitigation outreach efforts. It sounds good in the press, but it is just a secondary loss mitigation effort used in conjunction with the servicer’s own loss mitigation efforts. Perhaps it is responsible for some of the incremental improvement, but it’s hard to believe it accounts for much more.

Lenders’ Ability to Self-Regulate

“Skin in the Game” attempts to explain how lenders manage their retained credit risk when the VA insurance payment is insufficient to cover all loan losses.2 The “Skin in the Game” theory holds when lenders have exposure to losses they will adjust their lending policies to reduce their risk. This translates into tighter credit policies, like floors on credit scores or ceilings on DTIs. Having worked for companies with strong credit cultures that nearly failed in the recent financial crisis, I find it hard to believe privately held mortgage bankers can manage this risk. Quite the opposite, my experience tells me: 1) lenders always underestimate their residual credit risks, and 2) pressure for volume, market share, and profits quickly overwhelm any attempts to maintain credit discipline.

The notion that lender concentration in the VA originations market somehow means that those lenders have more capital or the ability to earn more money also makes little sense. Historically, the largest source of origination revenue is the capitalized value of the MSRs created when the loan is securitized. Over the past several years Ginnie Mae MSR prices have collapsed. This severely limits the profit margins from VA loans. Trust me, the top lenders are not making it up on volume.

Effect of Military Culture on VA Loans

So, what’s left? Military culture. This I believe. And not just because it is the only reason left. As the son of a retired Army colonel and the brother of both a retired Navy captain and a retired Marine Corps lieutenant colonel, I think I understand what the military culture is.

My view of military culture isn’t that veterans are more disciplined or responsible than the rest of the American public. My view of military culture is that institutional, structural, and societal differences make the military personnel workforce different than that of the general public. How?

Job Security

  • Active duty military personnel are not subject to mass layoffs or reductions in force typical in the business world.
  • Poor performing military personnel are typically eased out of the military and not fired.  This process of “getting passed over” spans several years and not weeks or months.
  • Most active duty military personnel have the flexibility to determine their exit strategy/retirement date, so they can defer when economic times are bad.

Retirement

  • Military personnel can retire with 50% pay of their base pay after 20 years of service.
  • This pension is received immediately upon retirement and is indexed to inflation.

Job Skills

  • A high percentage of retired military personnel re-enter the workforce and work for governmental agencies.
  • Military personnel typically leave active duty with more marketable skills than their similarly educated peers.
  • Active duty, retired, and former military personnel have jobs/careers/professions that are in higher demand than the rest of the American population.

Military Pay

  • Active and retired military pay is transparent, public, and socialized. The only variables are rank and years in service. The pay schedule provides for automatic pay increases based on the number of years in service and rank. Every two years you will get a pay increase. If you get promoted, you will get a pay raise. You know how much your boss makes. Female service-members make the same pay as their male counterparts.
  • Military pay is indexed to inflation.
  • In addition to their base pay, all military personnel are given a tax-free monthly housing allowance which is adjusted regionally.

Medical

  • All military families, active duty and retired, receive full medical care.
  • This health insurance has nearly no deductible or out-of-pocket expenses.
  • This means veterans don’t default due to catastrophic medical emergencies or have their credit capacity impacted by unpaid medical bills. 

It is for these reasons that I believe VA borrowers default less frequently than FHA borrowers. The U.S. military is not a conscripted force, but rather an all-volunteer force. The structural programs offered by the U.S. Government provide the incentives necessary for people to remain in the military.

The Federal Government has designed a military force with low turnover and backed by an institutionalized social safety net to help recruit, retain, and reward its personnel.  Lower default rates associated with the VA loan program are just the secondary benefits of a nation trying to keep its citizens safe.

So, on this Veterans Day, remember to thank a veteran for his service. But also, remember the efforts of the Federal Government to ease the difficulties of those protecting our nation.


[1] Housing Finance Policy Center Commentary, “VA Loans Outperform FHA Loans. Why. And What Can We Learn?”, Laura Goodman, Ellen Seidman, Jun Zhu.  Urban Institute – July 16, 201

[2] VA insurance is a first loss guaranty like MI insurance.  If the loss is greater than the insurance payment the mortgage servicer is responsible for the additional loss


Single Family Rental Securitization Market

The Single Family Rental Market

The single family rental market has existed for decades as a thriving part of the U.S. housing market.  Investment in single family homes for rental purposes has provided many opportunities for the American “mom and pop” investors to build and maintain wealth, prepare for retirement, and hold residual cash flow producing assets.   According to the National Rental Home Council (NRHC) (“Single-Family Rental Primer”; Green Street Advisors, June 6, 2016) as of year-end 2015, the single-family rental market comprised approximately 13% (16 million detached single-family rentals) of all occupied housing and roughly 37% of the entire United States rental market.

Single-Family Rental Securitization Structure

Introduce the credit crisis of 2008.  Limited credit for non-prime borrowers in combination with record setting delinquency and foreclosure rates prompted a significant reduction of housing prices. According to the S&P CoreLogic Case-Shiller U.S. National Home Price NSA Index, since the index’s launch in May 18, 2006 (initial index value = 184.38), national house prices had dropped 25% (index value = 138.5) by April 2012.

The market dynamic combination of low prices and post-crises rental demand along with highly restrictive mortgage credit qualifications alerted particular investors to an opportunity.  Specific private institutional investors, mostly private equity firms, began acquiring large quantities of distressed single family homes. According to the working paper entitled “The Emerging Economic Geography of Single-Family Rental Securitization” by the Federal Reserve Bank of San Francisco (Fields, Kohli, Schafran; January 2016) the entrance of these “large institutional investors into their new role as ‘corporate landlords’ [represented] a paradigm shift for the single-family rental market.”

Not only did they rehabilitate the homes and rent them out to non-prime borrowers, they then in turn introduced these assets into the capital markets by pledging the collateral and rental receipts into publicly issued REIT’s as well as issuing single-family rental securitizations (SFR).  The issuance of single family rental securitizations was a new concept utilizing an old vehicle, the issuance of a bankruptcy remote special purpose vehicle for the purpose of issuing debt via pledged collateral assets.

In this case, the collateral is generally a loan secured by a first priority mortgage (that was placed in an LP or LLC) backed by the pledging or sale of the underlying single family homes operated as rental properties (also normally placed in a previous LP or LLC).  Not only did this provide a strong exit strategy for investors because it allowed them to obtain immediate capital, but they were also able to increase their leveraged return on equity.

When Did Single-Family Rental Securitization Begin?

The first securitization transaction was issued in November 2013 by Invitation Homes (IH, 2013-1), a subsidiary of the Blackstone Group BX. As of July 2016, 32 single-borrower (26) and multi-borrower (six) SFR transactions have been issued. The table below provides a list of all SFR single and multi- borrower securitization transactions rated as of July 2016.123

Table: SFR Securitization Transactions Rated as of July 2016

Interestingly, the current inventory owned as well as securitized is only approximately 1 to 2% of the overall market.  Also of particular interest is the recent consolidation of institutions active in this market and the introduction of new participants.  American Homes 4 Rent (AM4R) acquired Beazer Rental Homes in July 2014 and Colony American Homes (Colony) merged with Starwood Waypoint Residential Trust (SWAY) in January 2016.  Subsequent to the Colony and SWAY merger, this newly formed company issued its own SFR securitization in June 2016 of approximately 3,600 properties with a loan balance of $536 million (CSH, 2016-1).  Moreover introducing themselves into the SFR securitization market was Home Partners of America (formerly Hyperion Homes, Inc.), which issued its first single-family rental securitization earlier this year (approximately $654mm, property count of 2,232).

Single-Family Rental Securitization Market Outlook

The question remains, is the SFR securitization market here to stay? On the one hand, issuance still appears to be strong; however, SFRs could be an efficient market’s response to the market dislocation of 2008, the effects of which may now appear to be fading away.  At a minimum this type of securitization demonstrates the effectiveness of the capital markets in moving quickly to fill the gaps left by the bursting of the housing bubble.


[1] Source: Kroll Bond Rating Agency, Inc. (KBRA)

[2] Source: www.businesswire.com

[3] Source: Yahoo Finance


Mortgage Insurance and Loss Severity: Causes and Effects of Mortgage Insurance Shortfalls

Mortgage Insurance and Loss Severity

This blog post is the first in a two-part series about Mortgage Insurance and Loss Severity. During the implementation of RiskSpan’s Credit Model, which enables users to estimate loan-level default, prepayment, and loss severity based on loan-level credit characteristics and macroeconomic forecasts, our team explored the many variables that affect loss severity. This series will highlight what our team discovered about Mortgage Insurance and loss severity, enabling banks to use this GSE data to benchmark their own MI recovery rates and help estimate their credit risk from MI shortfalls. RiskSpan reviewed the historical performance of Mortgage Insurers providing loan loss benefits between 1999 and 2015. Our analysis centered on Borrower and Lender-Paid Mortgage Insurance (referred to collectively as MI in this post) in Freddie Mac’s Single Family Loan-Level Dataset. Similar data is available from Fannie Mae, however, we’ve limited our initial analysis to Freddie Mac as its data more clearly reports the recovery amounts coming from Mortgage Insurers.

Mortgage Insurance Benefit Options

Exhibit 1: Mortgage Insurance Percentage Option Benefit Calculation

Mortgage Insurance Benefit = Calculated Losses x MI Percent Coverage Calculated Losses include:

  • UPB at time of default
  • Unpaid Interest
  • Other costs, such as attorney and statutory fees, taxes, insurance, and property maintenance.

Mortgage insurance protects investors against the event a borrower defaults. Mortgage Insurers have many options in resolving MI claims and determining the expected benefit, the amount the insurer pays in the event of a defaulted loan. The primary claim option is the Percentage Option, where the loan loss is multiplied by the MI percentage, as shown in Exhibit 1. Freddie Mac’s dataset includes the MI percentage and several loss fields, as well as other loan characteristics necessary to calculate the loss amount for each loan. The Mortgage Insurer will elect to use other claim options if they result in a lower claim than the Percentage Option. For example, if the Calculated Losses less the Net Proceeds from the liquidation of the property (i.e., net losses) are less than the Mortgage Insurance Benefit via the Percentage Option, the Mortgage Insurer can select to reimburse the net losses. Mortgage insurers can choose to acquire the property, known as the Acquisition Option. The mortgage insurer acquires the property after paying the full amount of the Calculated Losses on the loan to the investor. There were no instances in the data of Mortgage Insurers exercising the Acquisition Option after 2006.

Causes of Mortgage Insurance Shortfalls

Freddie Mac’s loan- level dataset allows us to examine loans with MI, which experienced default and sustained losses. We find that there are cases in which mortgages with MI coverage are not receiving their expected MI benefits after liquidation. These occurrences can be explained by servicing and business factors not provided in the data, for example: Cancellation: Mortgage Insurance may be cancelled either by non-payment of MI premium to the insurer or loan reaching a certain CLTV threshold. Per the Homeowners Protection Act of 1998, servicers automatically terminate private mortgage insurance (PMI) once the principal balance of the mortgage reaches 78% of the original value or if the borrower asks for MI to be cancelled once mark-to-market loan-to-value is below 80%. Denial: Mortgage Insurers may deny a claim for multiple factors, such as

  •  not filing a Notice of Default with the Mortgage Insurer within MI policy guideline’s time frame,
  • not submitting the claim within a timely period after the liquidation event,
  • inability to transfer title, or
  • not providing the necessary claim documentation, usually from underwriting, from loan origination to Mortgage Insurers at time of claim.

Rescission: Mortgage Insurers will rescind an MI claim but will refund the MI premiums to the servicer. Rescission of claims are usually linked to the original underwriting of the loan and might be caused by multiple factors, such as

  • underwriting Negligence by the lender,
  • third-party fraud, or
  • misrepresentation of the Borrower.

Curtailment: Mortgage Insurers will partially reimburse the filed claim if the expenses are outside of their MI policy scope. Examples of curtailment to MI claims include

  • excess interest, taxes, and insurance expenses beyond coverage provision of the Master Policy. Most current MI policies do not have these restrictions,
  • non-covered expenses such as costs associated with physical damage to the property, tax penalties, etc., and
  • delays in reaching foreclosure in a timely manner.

Receivership: During the mortgage crisis, several of the Mortgage Insurers (for instance Triad, PMI, and RMIC) became insolvent and the state insurance regulators placed them into receivership. For the loans that were insured by Mortgage Insurers in receivership, claims are currently being partially paid (at around 50% of the expected benefit) with the unpaid benefit being deferred. This unpaid benefit runs the risk of not being paid. These factors are evident in the data and our analysis as follows: Cancellations: The Freddie Mac dataset does not provide the MI in force at the time of default, so we cannot identify cases of cancellation. These cases would show up as an instance of no MI payment. Denials & Rescissions: Our analysis excludes any loans that were repurchased by the lender, which would likely exclude most instances of MI rescission and denial. In instances where the Mortgage Insurer found sufficient case to rescind or deny, Freddie Mac would most likely find sufficient evidence for a lender repurchase as well. Curtailments: The analysis includes the impact of MI curtailment. Receivership: The analysis includes the impact of Mortgage Insurers going into receivership.

Shortfalls of Expected Mortgage Insurance Recoveries

In the exhibits below, we provide the calculated MI Haircut Rate by Vintage Year and by Disposition Year for the loans in our analysis. We define the MI Haircut Rate as the shortfall between our calculated expected MI proceeds and the actual MI proceeds reported in the dataset. The shortfall in MI recoveries is separated into two categories: MI Gap and No MI Payment. 

  • MI Gap represents instances where some actual MI proceeds exist, but they are less than our calculated expected amount. The shortfall in actual MI benefit could be due to either Curtailment or partial payment due to Receivership. 
  • No MI Payment represents instances where there was no MI recovery associated with loans that experienced losses and had MI at origination. No payment could be due to Rescission, Cancellation, Denial, or Receivership.

For purposes of this analysis, the Severity Rate represented below does not include the portion of the loss outside of the MI scope. For example, in 2001, average severity rate was 30%, but only 19% was eligible to be offset by MI. This was done in order to give a better understanding of the MI haircut’s effect on the Severity Rate. Exhibit 1: Mortgage Insurance Haircut Rate by Vintage Years Mortgage Insurance Haircut Rate by Vintage Years We can observe an MI Haircut Rate averaging at 19.50% for vintages 1999 to 2011 with higher haircuts for the distressed vintages 2003 to 2008 at 23.50%. Exhibit 2: Mortgage Insurance Haircut Rate by Disposition Year Mortgage Insurance Haircut Rate by Disposition Year Our analysis shows the MI Haircut Rate prior to 2008 on average was 6.5% and steadily increased to an average of 25% from 2009 thru 2014. We will explain below. Exhibit 3: Mortgage Insurance Haircut Rate and Expense to Delinquent UPB Percentage by Months Non-Performing Mortgage Insurance Haircut Rate and Expense to Delinquent UPB Percentage by Months Non-Performing In this analysis, we observe the MI Haircut Rate steadily increased by the number of months between when a loan was first classified as non-performing and when a loan liquidated. This increase can be explained by increased curtailments tied to expenses that increase over time, such as expenses associated with physical damage of the property, tax penalties, delinquent interest, insurance and taxes outside the coverage period, and excessive maintenance or attorney fees. Interest, taxes, and insurance typically constitute 85% of all loss expenses. This analysis of mortgage insurance is an exploratory post into what causes the shortfall in MI claims and how those shortfalls can affect loss severity. RiskSpan will be addressing a series of topics related to Mortgage Insurance and loss severity.  In our next post we will address how banks can use this GSE data to benchmark their own MI recovery rates and help estimate their credit risk from MI shortfalls.


New Capital Planning Expectations for Large Financial Institutions and What It Means For You

The Federal Reserve Board (FRB) recently released regulatory guidance outlining its capital planning expectations for large financial companies. The guidance addresses many areas of the capital planning process where regulators are looking for continued improvement within large bank holding companies and attempts to clarify differences in the Fed’s expectations based on firm size and complexity. The guidance is effective for the 2016 CCAR cycle.

The Federal Reserve has provided separate guidance for two different categories of large financial institutions:

  1. LISCC Firms1 and ‘Large and Complex’ firms were provided capital planning guidance under SR 15-18, and
  2. ‘Large and Noncomplex’ firms were provided capital planning guidance under SR 15-19.

SR 15-18 Summary

Specifically, SR 15-18 applies to firms that:

  • Are subject to the LISCC framework,
  • Have total consolidated assets of $250 billion or more, or
  • Have consolidated total on-balance sheet foreign exposure of $10 billion or more.

For the largest and most complex firms, the guidance clarifies expectations that have been previously communicated to firms, including through past Comprehensive Capital Analysis and Review (CCAR) exercises and related supervisory reviews.

SR 15-19 Summary

SR 15-19 applies to firms and ‘Large and Noncomplex’ institutions that:

  • Are not otherwise subject to the LISCC framework,
  • Have total consolidated assets between $50 billion and $250 billion, and
  • Have total consolidated on-balance-sheet foreign exposure of less than $10 billion.

Implications of these capital planning guidelines

Both sets of guidelines (SR 15-18 and SR 15-19) lay out the governance, risk management, internal controls, capital policy, scenario design, and projection methodology expectations relating to the capital planning process. They also lay out some important distinctions between the two institution types relating to how models and model risk management are expected to be used.

We summarize some of the key differences between what is required of these two institution types in the table below. 

Current 2017 LISCC Portfolio Firms

According to the Federal Reserve, here are the current LISCC firms:

  • American International Group, Inc.
  • Bank of America Corporation
  • The Bank of New York Mellon Corporation
  • Barclays PLC
  • Citigroup Inc.
  • Credit Suisse Group AG
  • Deutsche Bank AG
  • The Goldman Sachs Group, Inc.
  • JP Morgan Chase & Co.
  • Morgan Stanley
  • Prudential Financial, Inc.
  • State Street Corporation
  • UBS AG
  • Wells Fargo & Company

[1] Large Institution Supervision Coordinating Committee (LISCC) – the Board of Governors of the Federal Reserve has the responsibility for the supervision of systemically important financial institutions, including large bank holding companies, the U.S. operations of certain foreign banking organizations, and nonbank financial companies that are designated by the Financial Stability Oversight Council (FSOC) for supervision by the Board of Governors. A list of LISCC firms can be found at http://www.federalreserve.gov/bankinforeg/large-institution-supervision.htm.


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