[I am away from the computer on a daily basis, and my access to e-mail is
and not timely. In my place are daily commentaries from a series of very
mortgage industry people with different backgrounds, and they have been
little direction about what to write about - the latest is below. Our views
or may not coincide, but I thank them for their time in volunteering and
To all those that have served or are serving on active duty: Thank you.
"On July 2, 1776 the Second Continental Congress voted to approve a
independence. After approving the vote for independence, attention was
at writing the Declaration of Independence. The Declaration of Independence
to be a statement explaining this decision to seek independence from Great
Thomas Jefferson was the principal author". As we should all know, The
of Independence was approved and signed on July 4. Enjoy the holiday.
"In a remarkable coincidence, both John Adams and Thomas Jefferson, the only
of the Declaration of Independence later to serve as Presidents of the
died on the same day: July 4, 1826, which was the 50th anniversary of the
The CFPB has just released its second proposals in a series of five. The
industries input. Go to http://www.consumerfinance.gov/knowbeforeyouowe/
and VOTE. I would recommend you print out the 2 proposals prior to voting.
are in the process of merging the GFE and TIL. I have met with the CFPB
Markets team on a number of occasions and they are very earnest in their
for industry responses. They received over 13,000 to the first proposal.
If you want to continue to participate you may register on the CFPB home
to receive their emails..
As Steve Emory wrote last week, our industry needs to speak up and get the
out. In the Spring of 2010, I got very frustrated and called the FRB's Mr.
Esq.. We had a very pleasant conversation about the FRB Rule and its
In his somewhat lengthy legalese, he gave me his version of what would
The next day I drove from NJ to DC and started banging on doors, so to
politicians in DC only know what they are told. Most of their information
from media sources or lobbyists. Many ranking officials did not know about
Rule on Originator Compensation as late as February 2011. It was simply
to me how disconnected our elected officials, both parties, are from the
that the 'boots on the street' have to experience.
As we approach our Day of Independence, it's time for you to exercise your
Go visit your elected official. You don't have to drive to DC, go visit them
their local district Talk to them about your issues and concerns. Your
are in district most of August. Call their DC office and ask for the
make an appointment today.
The following are two excerpts come from last week's Fannie Mae's Economics
Mortgage Market Analysis
"This month marks the two-year anniversary of the current economic
so far has been quite disappointing. The prospects for accelerating growth
grown dimmer recently with downward revisions of first-quarter activity and
economic data for the current quarter being downbeat. Markets have reacted
negatively, but the question is whether the repeated onslaught of global
has generated an overreaction. We believe the doomsayers are wrong;
growth is slowing appreciably and recession risks have risen."
"For 2011, we now expect economic growth to come in at 2.5 percent, a
from 2.9 percent in the previous forecast and more than a full percentage
lower than our forecast at the start of this year"
Now I'm only an arm chair economist and mortgage market analyst, but after
in the mortgage industry as a loan officer, broker and banker and the self
owner of a small business for most of that period, I, as most of you, can
fluff. And this is fluff. And not the marshmallow fluff we loved as kids.
Let's look at this again. We are in a "two year economic expansion", which
I must have missed the economic expansion. I'm perplexed. Are we expanding
it disappointing? After all the bad news of the past few years I would have
an expansion would be easily visible. Fannie openly notes that they are
revisions. Just the most recent is a revision from 2.9% to 2.5%. This new
is after a 1% reduction. So, is the report really saying that Fannie Mae is
targeting a 28% lower economic growth rate?
This week Rep. Scott Garrett (R-N.J.) and Rep. Carolyn Maloney (D-N.Y.) had
United States Covered Bond Act pass out of the Committee.
I recently had a conversation with Ian Coate's (NAIHP Vice President) and
advocate. Ian noted the following:
The business and profession of appraising is being phased out by external
The systemic appraisal protections, that high quality appraisals provide to
mortgage process, has been severely damaged by recent changes to the
guidelines and laws. The Home Valuation Code of Conduct (HVCC), which was
in May 2009 and then codified into federal law in the Dodd-Frank Act, has
single biggest destructive force to the appraisal profession in recent
With the average age of an appraiser at 57 years old, and the sharp decrease
appraiser trainees (caused by the downward pressure on appraisal fees), this
is facing the next mortgage related meltdown in 6-10 years due to a shortage
highly qualified appraisers. To become licensed as a certified appraiser,
possess an associate's degree or higher (soon to be a 4 year college
250 hours of approved appraiser education, and perform 2500 hours of trainee
in no less than 2 years time. With this large investment of time and
paired with the relatively low income expectations in the appraisal field,
is little hope of attracting highly qualified candidates to enter the
And despite financial institutions' desire to obtain property valuations
and cheaply, the alternative valuation methods such as AVMs and BPOs are
too unreliable and are dangerously inadequate when compared to traditional
The HVCC issue must be addressed immediately in order to correct a myriad of
consequences which ail our mortgage system.
Two River Mortgage & Investment
It's an NMLS world, right? The biennial course provider renewal process gets
beginning today and "we're starting to receive quite a few phone calls about
process. A list of providers who are due in July and a few tips to prepare
- As noted previously, NMLS moved from a fixed biennial renewal period to
rolling renewals based upon the two-year anniversary month of the initial
date. This means the date listed on the Approved Provider List may be
than the one listed on your initial approval letter. Providers should use
listed on the Approved Provider List which can be found here:
- Just like we do when you have a course up for renewal, you will be
least 30 days prior that your renewal period is approaching. - We will host
on July 12th for providers who are due in July and August to go over the
process, the application forms, and to answer questions. An invitation to
the webinar will be sent to those providers are due in these two months. The
July and August provider renewal list has been reposted. See
If you're interested, visit my twice-a-month blog at the STRATMOR Group web
located at www.stratmorgroup.com
. The current blog takes a look at near-term news for non-agency securities,
as jumbo residential loans. If you have both the time and inclination make a
on what I have written, or on other comments so that folks can learn what's
on out there from the other readers.
For archived commentaries, go to www.robchrisman.com
Copyright 2011 Rob Chrisman. All rights reserved. Occasional paid notices
This report or any portion hereof may not be reprinted, sold or
the written consent of Rob Chrisman.)
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