
Volume 7 | Issue 6 | Wednesday, January 09, 2008
|
 |
| Sponsored by: |
|
|
|
| |
 |
|
 |
|
|
| |
 |
“While having efficiency and power, customers who aren’t used to doing things online may also start. Increasingly, there will be competition with the larger financial institutions and its best to offer a positive and personal online experience.”
--Kim Dziedzec, user experience strategist at Chicago-based Vox Inc.
|
 |
|
|
 |
 |
|
 |
|
| |
|
|
| |
|
|
| |
Top National News
Residential Finance News
Customer-Oriented Banking Websites Crucial for Success
Refi Apps Jump, Rates Decline In MBA Weekly Survey
Commercial/Multifamily Finance News
HUD Rescinds Proposed MIP Increase
Vacancies Increase in Retail, Suburban Office, TWR Says
DealMaker of the Day
MBA News
MBA January FHA Courses
MBA Secondary Market Conference/Expo May 4-7
Spotlight: Residential
MBA Urges FASB Flexibility in Loan Modification Accounting
Forecasters: No Quick End to Housing Ills
Boston Globe (01/09/08); Appelbaum, Binyamin
In a Jan. 8 speech, Federal Reserve Bank of Boston President Eric Rosengren predicted that the housing market will not recover until June at the earliest; and said that with the market posting declines each quarter for the past two years, the downturn could be the longest in five decades. Rosengren talked about a cycle involving a reduction in consumer spending due to drops in home prices that put a damper on the broader economy, which in turn hinders spending on housing. He blamed the current downturn on the capital market efficiency that drove up residential prices during the housing boom, as lenders generated money to make additional mortgages through securitization. To put a swift end to the housing slump and attract investors and home buyers, Rosengren suggested that banks immediately report and write off bad loans and that home sellers set more realistic asking prices.
(More)
(Back To Top)
Fannie Mae Chief Expects Housing Slump to Linger
Charlotte Observer (NC) (01/09/08)
The housing market probably will not recover until 2010, Fannie Mae President and CEO Daniel Mudd speculated at a recent U.S. Chamber of Commerce event. To soften the blow to the overall economy, the executive believes lawmakers and lenders need to work together to assist borrowers whose payments will rise substantially in the coming years. However, with regard to the Bush administration plan to institute a five-year freeze on interest rates for certain subprime mortgages, Mudd offered only qualified support of the initiative.
(More)
(Back To Top)
Realtors' Index Shows Dip for Existing-Home Sales
New York Times (01/09/08) P. C7
The National Association of Realtors' pending home sales index fell to 87.6 in November, down 2.6 percent from October and off 19.2 percent year-over-year. NAR chief economist Lawrence Yun said it is difficult to pinpoint when sales will rebound, although he speculated that activity could bounce back as early as this spring or later in the year. When the trade group reports existing-home sales for all of 2007, it expects to announce a 12.7-percent decline to 5.65 million units from 6.48 million posted the prior year. As for the future, NAR anticipates a 0.9-percent rise in resales to 5.7 million in 2008 and a jump to 5.91 million in 2009.
(More - Registration Required)
(Back To Top)
Citi Revamps Mortgage Business
Wall Street Journal (01/09/08) P. C2
Citigroup Inc. recently restructured its U.S. home mortgage operations to align origination, servicing and capital-markets securitization. Additionally, the business overhaul will spur uniform mortgage products, policies and practices and allow the company to concentrate on lowering mortgage exposure when developing portfolio and capital goals. According to Carl Levinson of Citigroup's U.S. consumer lending group and Jamie Forese, co-CEO of markets and banking, "Aligning our existing U.S. mortgage businesses in this way will improve their overall effectiveness and allow us to better serve our existing clients while providing greater value to our shareholders."
(More - Subscription Required)
(Back To Top)
Countrywide Denies Rumors of Bankruptcy
New York Times (01/09/08) P. C9
Market speculation that Countrywide Financial Corp. is facing bankruptcy sent shares in the nation's largest mortgage lender down 28.4 percent to $5.47 on Jan. 8. Company officials denied it was considering such a move, saying there was "no substance to the rumor that Countrywide is planning to file for bankruptcy, and we are not aware of any basis for the rumor that any of the major rating agencies are contemplating negative action relative to the company." The rumors stem from reports about Countrywide's actions in borrowers' bankruptcy cases, including a case with Pennsylvania borrowers in which court records reportedly show the lender fabricated documents. Investors were already on edge about Countrywide due to the number of defaults on home loans by its customers.
(More - Registration Required)
(Back To Top)
In Brief: Residential Construction Value Falls in September
Wall Street Journal (01/09/08) P. B4
According to the U.S. Census Bureau, the value of private residential construction fell 2.5 percent in November from a month earlier, settling at a seasonally adjusted annual rate of $484.9 billion. Meanwhile, the value of private nonresidential construction rose 1.7 percent during the month to a seasonally adjusted annual rate of $375.8 billion.
(More - Subscription Required)
(Back To Top)
Housing Drop Saps Retail Landlords' Strength
Wall Street Journal (01/09/08) P. B1; Hudson, Kris
Driven by a nationwide housing boom, developers have produced more retail space nationwide since 2005 than office space, industrial facilities, rental apartments or any other commercial property category. However, just as much of that new space is nearing completion, demand is on the way down as mounting home foreclosures have thrown such previously hot markets as Phoenix and parts of Southern California into a slump. Even those retail landlords with fairly stable portfolios are having difficulties, as witnessed by Centro Properties Group's struggles to find an equity partner or buyer as impending debt maturities loom. Such instability could not only result in more vacant storefronts in shopping centers nationwide, but some projects could be scuttled altogether. The worst hit could be those cities such as Cleveland and Omaha, where there is an impending surplus of retail space in areas not previously thought of as retail hot spots.
(More - Subscription Required)
(Back To Top)
E-Trade Sells $3B Mgte-Backed Securities
CNNMoney (01/09/08)
Online brokerage E-Trade Financial Corp. on Jan. 9 disclosed the sale of about $3 billion worth of mortgage-backed securities and municipal bonds, one day after its losses on mortgage securities sent its shares to an all-time low. E-Trade's home equity loan portfolio ended the year with under $12 billion in balances. The discount broker's new chief operating officer, Robert Burton, will head a special committee charged with "aggressively" reducing risk in its real estate portfolio.
(More)
(Back To Top)
|
|
|
 |
| Customer-Oriented Banking Websites Crucial for Success |
MBA (1/9/2008 ) Palaparty, Vijay
The usability aspects of consumer banking web sites hold immense importance—customers’ positive experiences could have resounding effects on business growth. But banks neglecting customer perspectives could lose current and future business—without customers even clicking the mouse past the homepage.
“Banks need to support both existing and potential customers and that experience should be both pleasant and efficient,” said Kim Dziedzec, user experience strategist at Chicago-based Vox Inc. “Customers do appreciate and notice up-to-date look and feel of websites and banks should make an effort to keep them current. The homepage is where customers make judgment on the overall site and are there to conduct business and have their questions answered. What banks should do is draw them in with potential offers and cross-sell while being careful not to overwhelm.”
Vox’s Banking Mind Model Study, which analyzed customer experiences on consumer banking industry websites in the fourth quarter of last year, revealed that more than two-thirds of the average bank home page is devoted to products and special offers. Increasingly, banks have dropped unessential elements to focus instead on pushing other products, especially credit cards. Many of the banks in the study have mortgage arms, but considering current market conditions, such products and services are not currently in the spotlight.
“Credit cards and CDs are on products and services lists more than mortgages—there is bigger profit margin on these products, especially credit cards,” Dziedzec said. “Financial institutions support one-stop shopping for customers’ needs—those sometimes also include insurance. Even if mortgages aren’t being pushed at the moment, they are still part of the cross-selling strategy and most customers will consider their own bank when looking for a mortgage. The affinity evolves out of the trust and relationship established with the bank. But right now, banks are pulling back on pushing mortgages and are looking for better risk—but they will switch back when the market turns around.”
The number of customers banking online is increasing steadily, though the rate of growth has slowed in recent years. In 2007, New York-based eMarketer predicted that that 80 million—43 percent of the U.S. adult population—would bank online in 2008—an increase of 9.5 percent over 2006. A bank’s online customer portal is critical in serving customers and retaining them while also attracting new business.
Ninety-one percent of online customers who have a bad experience on a self-service web site will not return and on average, a bank that spends 10 percent on of their project budget on usability experiences an increase of 100 percent in sales conversion rate, 150 percent increase in site traffic and a 200 percent increase in the use of site features.
The study analyzed page elements and layouts of banking industry web sites to gauge customer experiences and also the bank’s focus and strategy on the customer. Improvements in web sites were found in aspects such as allowing customers control over text and image size—a result of variation in internet browsers. Enhanced search functions on web sites also improved over previous studies, including detecting common misspellings. Other trends were the phasing out of institutional images—such as stock photos of customers—that were replaced by product promotions.
Banks are also pushing to create and improve experiences for those who bank from the palm of their hand—mobile banking. By 2010, 35 percent of online banking households are expected to use mobile banking. As accessibility rises, issues of security also increase. On average, banks allocated 4.1 percent of their homepage to security and most sites place security information adjacent to customer access. Chase Bank, New York, and Atlanta-based SunTrust devote more than 5 percent to security while Citibank, New York, HSBC, Wilmington, Del., Washington Mutual, Seattle, and National City, Cleveland, devote less than 1 percent.
“There is a definite increase in security and from the customers’ perspective, they are getting more comfortable,” Dziedzec said. “Customers are less worried about the security of banking online than last year. As of 2007, only 14 percent of offline-only users attributed their avoidance of online banking to security concerns. In 2006, this figure was 53 percent —a difference of 39 percent in just one year. This could only be explained by word-of-mouth factor. If customers see that friends and relatives are banking online, then they are more than likely to believe that it is a safe thing to do. Additionally, banks are offering more security layers such as putting user names and passwords on different pages—it’s definitely a word-of-mouth reason.”
Citibank, Bank of America, both of Charlotte, N.C., and Wells Fargo, San Francisco, ranked highest in the usability analysis. They excelled in more than one category but didn’t excel in all, leaving room for improvement to enhance customer experiences. In terms of catering to non-English speaking customers, many bank sites fail to offer Spanish-language versions—a gap that needs to be addressed as the Hispanic population grows nationally.
“Specific mortgage banking web sites could also focus efforts on creating cleaner, less overwhelming websites while also adding human touch,” Dziedzec said. “While having efficiency and power, customers who aren’t used to doing things online may also start. Increasingly, there will be competition with the larger financial institutions and its best to offer a positive and personal online experience.”
(Back To Top)
| | |
| Refi Apps Jump, Rates Decline In MBA Weekly Survey |
MBA (1/9/2008 ) Kemp, Carolyn
Declining interest rates contributed to an uptick in refinance activity, according to the Mortgage Bankers Association’s Weekly Mortgage Applications Survey for the New Year’s holiday-shortened week ending January 4.
The Market Composite Index rose to 706.0, an increase of 32.2 percent on a seasonally adjusted basis from 533.9 one week earlier, the week between the Christmas and New Year holidays. On an unadjusted basis, the Index increased 81.1 percent compared with the previous week and was up 8.7 percent compared with the same week one year earlier. The four-week moving average for the Market Index fell by 4.1 percent to 624.4 from 650.8.
The seasonally adjusted Refinance Index increased 53.9 percent to 2494.2 from 1620.9 the previous week. The four-week moving average fell by 4.5 percent to 2031.0 from 2127.4. The refinance share of mortgage activity increased to 57.7 percent of total applications from 50.9 percent the previous week.
The seasonally adjusted Purchase Index increased 14.7 percent to 414.0 from 360.8 one week earlier. On an unadjusted basis, the Purchase Index increased 56.2 percent to 251.8 from 161.2 the previous week. The four-week moving average was down 3.5 percent to 397.9 from 412.4.
The seasonally adjusted Conventional Index increased 34.1 percent to 1015.3 from 757.4 the previous week; the seasonally adjusted Government Index increased 18.2 percent to 190.4 from 161.1 the previous week.
The average contract interest rate for 30-year fixed-rate mortgages decreased to 5.73 percent from 6.05 percent, with points increasing to 1.10 from 1.05 (including the origination fee) for 80 percent loan-to-value (LTV) ratio loans.
The average contract interest rate for 15-year fixed-rate mortgages decreased to 5.21 percent from 5.61 percent, with points increasing to 1.18 from 1.02 (including the origination fee) for 80 percent LTV loans.
The average contract interest rate for one-year adjustable-rate mortgages increased to 6.04 percent from 6.00 percent, with points decreasing to 0.99 from 1.00 (including the origination fee) for 80 percent LTV loans. The ARM share of activity decreased to 9.3 percent from 9.8 percent of total applications from the previous week.
The survey covers 50 percent of all U.S. retail residential mortgage originations, and has been conducted weekly since 1990. Respondents include mortgage bankers, commercial banks and thrifts.
(Back To Top)
|
|
 |
| HUD Rescinds Proposed MIP Increase |
MBA (1/9/2008 ) MBA Staff
HUD announced yesterday that it intends to rescind a Notice published in October that would have increased the mortgage insurance premiums on a number of multifamily programs.
HUD noted that the “market has changed significantly” since the original FY 2008 budget proposal was made. Additionally, the Mortgage Bankers Association produced “solid evidence” that the programs affected were providing affordable housing, prompting HUD to determine that an MIP increase at this time was “not appropriate.”
“Thanks go to those MBA members who participated in lobbying Congress and the Administration on this issue as well as to those who submitted data for MBA’s survey,” said Cheryl Malloy, MBA’s senior vice president of multifamily and governance. “There was no indication provided as to whether the Administration’s FY 2009 budget proposal will contain an MIP increase. However, we are hopeful that FHA modernization legislation prohibiting an unwarranted increase will become law prior to October 1.”
(Back To Top) |
| |
| Vacancies Increase in Retail, Suburban Office, TWR Says |
MBA (1/9/2008 ) Murray, Michael
As the clock ran down on 2007, vacancy rates increased in retail and suburban office property markets—up from the fourth quarter of 2006, according to statistics from CBRE Torto Wheaton Research, Boston.
Vacancy rates on retail centers —consumer-related commercial real estate as opposed to business-related CRE—increased to 9.8 percent for the fourth quarter 2007 from 8.7 percent a year ago. Retail vacancy rates ended the year up by 40 basis points compared to one quarter ago, or 110 basis points from the end of 2006.
“The news from the final month of the holiday shopping—the day after Thanksgiving to midnight on Christmas Eve—was abysmal,” the research firm said. “Estimations showed that core retail sales during this time were only up 2.4 percent compared to one year ago. This is far below the expected worst case scenario forecasts of around 3.5 percent. Consumers continue to be negatively impacted by the elements that have been hurting them throughout 2007, such as the housing slowdown and high gas prices.”
Office properties had an overall improvement in their vacancy rates—down 10 basis points to 12.5 percent. Downtown office markets performed better than suburban markets, ending the year at 9.6 percent, down from 10.2 percent at the end of 2006, as suburban office rates rose to 14.2 percent from 13.9 percent.
The disparity in the pipeline of new construction, feeding supply to suburban markets at a higher rate than to downtown markets, was one reason for the difference, according to TWR. Its research showed most markets—29 out of 57—experienced vacancy rate declines, but more than half of all suburban markets experienced an increase in vacancy rates.
Meanwhile, industrial properties, another business-related property-type, ended the year with a 9.4 percent vacancy rate—same as year-end 2006.
Raymond Torto, principal of CBRE Torto Wheaton Research, said the fourth quarter results were consistent with the research firm’s expectations. “The outlook is for more of the same in the first half of 2008, but long-term, we expect these sectors to perform well for investors,” he said.
Vacancy rates consistently fell since the second quarter of 2003—for nearly 4.5 years—and the industrial market was improving since the first quarter of 2004. However, TWR observed vacancy rate increases in both sectors with larger increases in markets strongly affected by the recession in housing.
Orange County, Calif., for example, home of many subprime lenders, had vacancy rate increases in office and industrial from 8.3 percent to 14.5 percent. Phoenix and Las Vegas also had large increases, according to TWR, with Phoenix’s office and industrial vacancy rate increases to 15.9 percent during the year from 11.9 percent at the end of 2006. In Las Vegas, vacancy rates now at 15.5 percent jumped from 9.4 percent. Both markets, however, were hurt in 2007 by falling demand in office and industrial and increases in new supply.
(Back To Top) |
| |
| DealMaker of the Day |
MBA (1/9/2008 ) Murray, Michael
CBRE | Melody’s Denver office arranged more than $58.7 million in financing for an office property in South Carolina and new construction industrial and multifamily acquisition and renovation in Colorado.
Eric Tupler, managing director of CBRE| Melody’s Denver office, arranged first mortgage financing of $16.3 million for the acquisition of Fontaine Business Park in Columbia, S.C. through Greenwich Capital, Greenwich, Conn. The borrower consists of a series of tenant-in-common interests, managed by sponsor U.S. Commercial, a subsidiary of U.S. Advisors, Napa, Calif.
The fixed loan carries a 6.6 percent rate for the 10-year term, with three years of interest-only amortization, and no leasing reserve collections for the first three years of the loan term.
Fontaine Business Park—82 percent leased to nearly 20 tenants—has limited rollover until 2012. The four-building, 253,038 rentable square-foot office park is in the Northeast market, second-largest for suburban office market in Columbia.
“Given the current market conditions, the financing assignment required patience and cooperation between both buyer and seller,” Tupler said. “We appropriately set expectations with both buyer and seller prior to moving forward with the transaction which ultimately allowed us to execute in a very smooth manner.”
Tupler and Mike Easter, vice president in the Denver office, arranged $37.5 million in debt and joint venture equity financing on behalf of RedHill Realty Investors for the acquisition and renovation of The Mezzo apartments in Denver, Colo., through Fannie Mae. The total debt and equity financing represented 98 percent of the total cost of the acquisition and renovation.
The 315-unit Mezzo—built in 1953—was 94 percent occupied at closing. The borrower budgeted nearly $13,300 per unit for renovations to the property. Units will undergo complete interior upgrades that include entire renovations to the kitchens and bathrooms as well as new flooring and paint. Common area improvements to the property will include updating the fitness center, elevators and common areas, according to CBRE | Melody.
Meanwhile, Tupler and Baxter Fain, vice president in the Denver office, arranged owner-occupied permanent financing of $4.93 million for purchase of a newly constructed industrial property 100 percent leased to Pella Windows in Denver.
An undisclosed portfolio lender provided the financing on behalf of Bevis Investment Co. LLC, an entity related to the tenant. Financing includes 85 percent loan- to-purchase price, 10-year loan term with a 30 –year amortization at a fixed-rate of 7.25 percent.
“The loan put in place was ideal for this owner-occupied transaction giving the borrower/tenant 85 percent leverage, flexible prepayment, funding the loan with a temporary certificate of occupancy, and allowing the tenant to sublease all or a portion of the building to manage any future needs for the owner/tenant,” Fain said.
The building has 66,008 square feet.
(Back To Top) |
 |
| MBA January FHA Courses |
MBA (1/9/2008 ) Harris, Mary
CampusMBA, the education arm of the Mortgage Bankers Association, announces two new instructor-led courses: FHA Fundamentals and FHA Underwriting & Operations, which will take place on consecutive days (January 10-11) at MBA headquarters in Washington, D.C.
FHA Fundamentals
MBA Headquarters, January 10
http://www.campusmba.org/products/default.aspx?product_code=E2801618/REGIS
This new CampusMBA course is designed for anyone who is new to FHA lending and those who need to refresh their knowledge of FHA guidelines. With the improvements made to FHA lending over the past two years, this workshop covers latest developments and keeps you abreast of recent procedures and regulations to FHA loans.
FHA Underwriting & Operations
MBA Headquarters, January 11
http://www.campusmba.org/products/default.aspx?product_code=E2801620/REGIS
This course is designed specifically for processors, underwriters and quality control staff responsible for the details within the FHA loan process. It takes an extensive look into the processing and underwriting requirements of FHA lending guidelines and compliance. Learn developments with the back end of the lending process, closing and quality control.
Who Should Attend:
• Underwriters
• Processors
• Loan originators
• Production managers
• Loan sales teams
Registration Information:
Register for BOTH FHA Fundamentals and FHA Underwriting & Operations and save. To take advantage of this special bundle offer, register by phone at (800) 348-8653.
Registration after December 7 (For individual courses): MBA Members $199/Non-members $299.
Registration after December 7 (Bundle price): MBA Members $299/Non-members $399.
To qualify for the member rate, you must work for a company that is a member of the Mortgage Bankers Association
To register online, click the links above; you can also call (800) 348-8653 or download the registration form at www.campusmba.org/files/ClassroomProgramRegistrationForm.pdf and fax it to (202) 721-0166.
(Back To Top) |
| |
| MBA Secondary Market Conference/Expo May 4-7 |
MBA (1/9/2008 ) Jones, Coeli
Save the date for the Mortgage Bankers Association’s National Secondary Market Conference & Expo 2008. The conference, “Succeed in a Changing Market,” takes place May 4-7 at the Hynes Convention Center in Boston.
As rapid changes in the mortgage industry create difficult setbacks and hidden opportunities for investors, this conference focuses on creative and forward-looking ways for you and your company to meet the challenges of today's marketplace and come out ahead.
Join industry leaders and your peers to exchange ideas and strategies on topics such as:
• A perceived credit crunch
• Tighter credit standards
• Lack of liquidity in the private label MBS market
• GSE portfolio caps
• GSE reform
Register before April 14, 2008 to save on your registration fee. Make your hotel reservations at the Sheraton Boston before April 8, 2008. Room rates are $238/night and up. Register today: call (800) 793-6222 or visit the conference Web site for more information: http://events.mortgagebankers.org/secondary2008/default.html.
(Back To Top) |
|
| MBA Urges FASB Flexibility in Loan Modification Accounting |
MBA (1/9/2008 ) Sorohan, Mike
The Mortgage Bankers Association, in a letter to the Financial Accounting Standards Board, urged FASB to allow lenders to modify residential mortgage loans unhindered by concerns about how they will be required to account for the loans after the fact.
The letter, written in response to specific questions raised by FASB as a result of earlier MBA correspondence, recommended that lenders be allowed to measure impairments of modified residential mortgage loans that they hold for investment under FAS 5, Accounting for Contingencies, instead of FAS 114, Accounting by Creditors for Impairment of a Loan. MBA said that measuring impairments of such loans under FAS 114 would be operationally difficult for lenders that presently do not have the systems capability to project cash flows on modified loans as required under that accounting standard.
“MBA's involvement with this issue is important to note because it provides further evidence of our members' commitment to making loan modifications,” said Alison Utermohlen, MBA’s senior director of government affairs and author of the letter. “By contacting the FASB, MBA is demonstrating our sincere interest in moving forward by removing all impediments to these modifications.”
The letter makes the following points:
• MBA said potentially “tens, and perhaps hundreds of thousands of residential mortgage loans that are held for investment could be modified and therefore subject to the measurement guidance in FAS 114 initially and on an ongoing basis in the future. Consequently, MBA believes this issue is relevant to all companies that hold such loans for investment whose terms may be changed in the future to make them more affordable to borrowers. MBA also believes that the challenge of applying the guidance in FAS 114 would be comparable among large and small companies given their relative loan portfolios and systems capabilities.”
• FAS 114 contains a scope exception for smaller-balance homgenous loans that are collectively evaluated for impairment. However, once a loan has been mofdified and is deemed a “troubled debt restructuring” under the accounting literature, it becomes subject to the measurement guidance in that statement. MBA said that had the mortgage industry and FASB known during the drafting of FAS 114 that thousands of residential mortgage loans could be modified in the same reporting periods that the scope exception in FAS 114 would have been written more broadly to include loans that are modified, as well as those that are unmodified.
• Once a loan is subject to FAS 114, it must be measured for impairment by discounting the projected cash flows to be received at the original contractual interest rate. As a practical expedient, the loan may be valued based on 1) the value of the underlying collateral costs to sell or 2) quoted market prices for the loan.
• FAS 5 would capture the pure credit loss attributable to not receiving the carrying value of a loan based on an evaluation by the lender as of the reporting date of the probability that some amount of that value will not be recovered. This amount would likely differ from the loss amounts that would be produced under any of the three valuation approaches provided for under FAS 114 because they take into account factors beyond the probability of recovery of an asset’s current carrying value.
• MBA said many lenders simply do not have the systems capability to measure impairments of modified smaller-balance residential mortgage loans using a discounted cash flow approach. “Such an approach would involve considerations of the impact of changes to specific loan terms on probable future prepayments and defaults for the purpose of projecting future cash flows,” MBA said. “For example, lenders' systems would have to consider and quantify for valuation purposes a variety of possible changes to borrowers' loan terms, including changes to the cash flows resulting from a modification where a borrower's initial interest rate is extended for a period of time as opposed to a modification where a borrower's principal and interest payments in arrears are forgiven.”
• Even if impairment for thousands of loans could be calculated “off-line,” the measured impairment would have to be manually fed into the loan accounting system and accounted for separately for subsequent accounting purposes, including accretion of the valuation allowance due to the passage of time. This would be extremely time-consuming and would likely involve additional staff dedicated to this purpose.
• FAS 114 would require companies to calculate best estimates on a loan-by-loan basis if the loans are modified differently and therefore not evaluated as part of a pool. Accordingly, the loan-by-loan systems limitations exist at institutions both large and small, and regardless of whether they securitize or not.
• FAS 114 would be “onerous” to apply because of the requirement that future cash flows be estimated at every reporting period for the remaining life of a loan, or pool of loans. “Moreover, loans that could not be grouped together (for reasons relating to the nature of a particular modification) would still have to be evaluated separately,” MBA said. “Thus, lenders would still be burdened with projecting cash flows for some individual loans, as well—potentially—as some large pools of loans. The burden of complying with FAS 114 going forward would, therefore, still be great for most lenders.”
• MBA members said they have the means to estimate losses on loans that may be modified in the future under FAS 5, which likely will include comparing historical default rates on pre-existing and existing loans with terms and borrowers that are comparable to the newly modified loans.
• MBA members said the requirement under FAS 114 to obtain appraisals of thousands of single family homes, or quoted market prices for modified smaller-balance loans, initially and on an ongoing basis as an alternative to measuring impairments under FAS 114 using discounted cash flow analyses would be too costly. “It would also be difficult to obtain the information on a timely basis and, once obtained, it could be subject to challenge, particularly in the case of quoted market prices which can vary widely depending upon the sources of bids,” MBA said. “The requirement to obtain appraisals or quoted market prices initially and at the end of every period for which financial data is reported would likely involve the hiring of additional staff for this purpose alone.”
• A FAS 5 measurement would capture the extent to which the carrying value of a loan would not be recovered which is a cost-based measurement, similar to the requirement to carry loans held for investment at cost under FAS 65. By contrast, a discounted cash flow approach under FAS 114 would capture the effect of not receiving interest that might have been received absent the modification despite the greater likelihood that the loan would have gone into foreclosure (i.e. resulting in a loss of any and all future interest), which is neither a cost-based nor a market-based measurement.
Additionally, MBA sent the letter to the Securities and Exchange Commission and the federal banking agencies.
(Back To Top)
|
|
ABOUT MBA Newslink
Publisher: Cheryl Crispen, Senior Vice President - Communications and Marketing
Editor: Mike Sorohan 202/557-2855
MSorohan@mortgagebankers.org
Deputy Editor: Michael Murray 202/557-2851
MMurray@mortgagebankers.org
Senior Staff Writer: Vijay Palaparty 202/557-2904 VPalaparty@mortgagebankers.org
Advertising Opportunities: Bill Farmakis 203/834-8832
bill@jlfarmakis.com
Jonathan L. Kempner, President and CEO, Mortgage Bankers Association
MBA Newslink, a
daily electronic publication, is a member benefit free to employees of MBA member companies, and available by
paid subscription to non-members. For membership information, visit MBA's website at
http://www.mortgagebankers.org/AboutMBA/membership.
If this email has been forwarded to you, please visit
http://www.mortgagebankers.org/NewsandMedia/MBANewsLink/NewslinkSubscribe.htm to subscribe.
To view the Newslink archives, click
here.
Any reprints or other use of these articles in whole or in substantial part, in any medium, requires advance written permission from the Mortgage Bankers Association. For reprint information on stories in MBA Newslink, please contact Stefanie Lauff at (800) 394-5157 Ext. 26.
Abstracts
Copyright (c) 2007 Information, Inc., Bethesda, Maryland USA. (Legal Information)
The links at the end of each abstract are to the publisher, publication, or
article. Some links may require registration or subscription. Information, Inc.
is not affiliated with the referenced publications.
(Back To Top)
|
|
Copyright © 2007 Mortgage Bankers Association. All rights reserved.
1919 Pennsylvania Ave. NW Washington, DC 20006-3404
(202) 557-2700, All Rights Reserved.
http://www.mortgagebankers.org/
MBA Newslink Legal Information
If you have
difficulties reading this HTML email, please go to http://www.mortgagebankers.org/mbanewslink/issues/2008/01/09.asp. |
|
|