[I am away from the computer on a daily basis, and my access to e-mail is
sporadic
and not timely. In my place are daily commentaries from a series of very
knowledgeable
mortgage industry people with different backgrounds, and they have been
given very
little direction about what to write about - the latest is below. Our views
may
or may not coincide, but I thank them for their time in volunteering and
helping
out.]
Note:
To all those that have served or are serving on active duty: Thank you.
Independence Day:
"On July 2, 1776 the Second Continental Congress voted to approve a
resolution of
independence. After approving the vote for independence, attention was
directed
at writing the Declaration of Independence. The Declaration of Independence
was
to be a statement explaining this decision to seek independence from Great
Britain.
Thomas Jefferson was the principal author". As we should all know, The
Declaration
of Independence was approved and signed on July 4. Enjoy the holiday.
"In a remarkable coincidence, both John Adams and Thomas Jefferson, the only
signers
of the Declaration of Independence later to serve as Presidents of the
United States,
died on the same day: July 4, 1826, which was the 50th anniversary of the
Declaration."
CFPB:
The CFPB has just released its second proposals in a series of five. The
CFPB wants
industries input. Go to http://www.consumerfinance.gov/knowbeforeyouowe/
[http://r20.rs6.net/tn.jsp?llr=zy6u9cdab&et=1106312194052&s=8721&e=001M6pGSU
VzFruloCXhQMxAs7Ia_Di5hmIcw8PhZwgji135BP1MQDbdD2ggtojorvc-py6kqGsczaBcFEMYMK
93c6z0M3MEz1hcmvMK29GrTYIHV7kYiKxpXKLQ1fzRWBl1pdDeCV_qaa7XBWtJ8BewHw==]
and VOTE. I would recommend you print out the 2 proposals prior to voting.
They
are in the process of merging the GFE and TIL. I have met with the CFPB
Mortgage
Markets team on a number of occasions and they are very earnest in their
request
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
page www.cfpb.gov
[http://r20.rs6.net/tn.jsp?llr=zy6u9cdab&et=1106312194052&s=8721&e=001M6pGSU
VzFrt83bHPhjlHd-YKbvXTVNlDCYHyza8rCS71h1eN14KRx1qYFWUz9ReKUdpwxAuPbX-E0VLSML
TOXr5qFAtSzpt_ZTaCFf92uDk=]
to receive their emails..
Political Advocacy:
As Steve Emory wrote last week, our industry needs to speak up and get the
truth
out. In the Spring of 2010, I got very frustrated and called the FRB's Mr.
Mondor,
Esq.. We had a very pleasant conversation about the FRB Rule and its
integration.
In his somewhat lengthy legalese, he gave me his version of what would
transpire.
The next day I drove from NJ to DC and started banging on doors, so to
speak. Our
politicians in DC only know what they are told. Most of their information
comes
from media sources or lobbyists. Many ranking officials did not know about
the FRB
Rule on Originator Compensation as late as February 2011. It was simply
amazing
to me how disconnected our elected officials, both parties, are from the
reality
that the 'boots on the street' have to experience.
As we approach our Day of Independence, it's time for you to exercise your
independence.
Go visit your elected official. You don't have to drive to DC, go visit them
in
their local district Talk to them about your issues and concerns. Your
elected officials
are in district most of August. Call their DC office and ask for the
Scheduler and
make an appointment today.
Fannie Mae:
The following are two excerpts come from last week's Fannie Mae's Economics
and
Mortgage Market Analysis
http://www.fanniemae.com/media/pdf/economics/2011/Summary_062011.pdf;jsessio
nid=REGC0CEPB5QEDJ2FQSISFGI
[http://r20.rs6.net/tn.jsp?llr=zy6u9cdab&et=1106312194052&s=8721&e=001M6pGSU
VzFrsgDsm6sFfsbB5VJhNetYgvpqTwHcXuLnTagF9a4iaWBGX-XP4DgrSgCUkdJWcGl_v3-U-02b
tsiXnPdvs5_CQwgB6gkpF8tvN-Fs4zletk8G_l25LyitU_nQclc0WQ6dcaqMEtE7eBgy8piXwxNz
OYNfuMLrYXsqA2xZG5ePvL9X21HZ4gely0RADoFS5_z6c8a-evRMH7eLf0-7umRnLwptgScLvKs7
A=]
:
"This month marks the two-year anniversary of the current economic
expansion, which
so far has been quite disappointing. The prospects for accelerating growth
have
grown dimmer recently with downward revisions of first-quarter activity and
most
economic data for the current quarter being downbeat. Markets have reacted
quite
negatively, but the question is whether the repeated onslaught of global
shocks
has generated an overreaction. We believe the doomsayers are wrong;
nevertheless,
growth is slowing appreciably and recession risks have risen."
"For 2011, we now expect economic growth to come in at 2.5 percent, a
downgrade
from 2.9 percent in the previous forecast and more than a full percentage
point
lower than our forecast at the start of this year"
Now I'm only an arm chair economist and mortgage market analyst, but after
25yr
in the mortgage industry as a loan officer, broker and banker and the self
employed
owner of a small business for most of that period, I, as most of you, can
recognize
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
is "disappointing".
I must have missed the economic expansion. I'm perplexed. Are we expanding
or is
it disappointing? After all the bad news of the past few years I would have
thought
an expansion would be easily visible. Fannie openly notes that they are
having downward
revisions. Just the most recent is a revision from 2.9% to 2.5%. This new
target
is after a 1% reduction. So, is the report really saying that Fannie Mae is
now
targeting a 28% lower economic growth rate?
Congress:
This week Rep. Scott Garrett (R-N.J.) and Rep. Carolyn Maloney (D-N.Y.) had
their
United States Covered Bond Act pass out of the Committee.
HVCC
I recently had a conversation with Ian Coate's (NAIHP Vice President) and
appraiser
advocate. Ian noted the following:
The business and profession of appraising is being phased out by external
forces.
The systemic appraisal protections, that high quality appraisals provide to
the
mortgage process, has been severely damaged by recent changes to the
appraisal
guidelines and laws. The Home Valuation Code of Conduct (HVCC), which was
implemented
in May 2009 and then codified into federal law in the Dodd-Frank Act, has
been the
single biggest destructive force to the appraisal profession in recent
years.
With the average age of an appraiser at 57 years old, and the sharp decrease
in
appraiser trainees (caused by the downward pressure on appraisal fees), this
country
is facing the next mortgage related meltdown in 6-10 years due to a shortage
of
highly qualified appraisers. To become licensed as a certified appraiser,
one must
possess an associate's degree or higher (soon to be a 4 year college
degree), take
250 hours of approved appraiser education, and perform 2500 hours of trainee
experience
in no less than 2 years time. With this large investment of time and
resources
paired with the relatively low income expectations in the appraisal field,
there
is little hope of attracting highly qualified candidates to enter the
profession.
And despite financial institutions' desire to obtain property valuations
more quickly
and cheaply, the alternative valuation methods such as AVMs and BPOs are
simply
too unreliable and are dangerously inadequate when compared to traditional
appraisals.
The HVCC issue must be addressed immediately in order to correct a myriad of
negative
consequences which ail our mortgage system.
Brian Benjamin
Two River Mortgage & Investment
Editor's note:
It's an NMLS world, right? The biennial course provider renewal process gets
underway
beginning today and "we're starting to receive quite a few phone calls about
the
process. A list of providers who are due in July and a few tips to prepare
follow:
- As noted previously, NMLS moved from a fixed biennial renewal period to
monthly
rolling renewals based upon the two-year anniversary month of the initial
approval
date. This means the date listed on the Approved Provider List may be
further out
than the one listed on your initial approval letter. Providers should use
the date
listed on the Approved Provider List which can be found here:
http://mortgage.nationwidelicensingsystem.org/courseprovider/Documents/NMLS%
20Approved%20Course%20Providers.pdf
[http://r20.rs6.net/tn.jsp?llr=zy6u9cdab&et=1106312194052&s=8721&e=001M6pGSU
VzFrsd4ZZshUPXdk9y0mgIKzBUZdXQC1O-ZMayfYj3i1nBjRXIwTkZ_kRKnfQJrBfB4AyqCqArYt
9cxPJrqcDiZWHjSKgwTZft3xlxZKkJgQOnTnstLN_3iGlOXIPqyi10zFFsRcELQMzPBqieZM6_4U
CqGiN5jMVBjMF92txHPoGq3hqXfqdRwUSOkCy5Y_S8PRMnJcS4Sqf2_XtCtQwZo39Ikxvr5r0cG4
z54hvm2k50Pg==]
- Just like we do when you have a course up for renewal, you will be
notified at
least 30 days prior that your renewal period is approaching. - We will host
a webinar
on July 12th for providers who are due in July and August to go over the
renewal
process, the application forms, and to answer questions. An invitation to
attend
the webinar will be sent to those providers are due in these two months. The
updated
July and August provider renewal list has been reposted. See
http://nmlseducation.wordpress.com/2011/06/21/439
[http://r20.rs6.net/tn.jsp?llr=zy6u9cdab&et=1106312194052&s=8721&e=001M6pGSU
VzFrtN0HAe9HLouHikqxfqjrb0XFjqtqPU8LkUp6z5ceCeRTk956pSKTqOlJDAjLB4xyPUSCloQo
b434My6n743SzoLYdhwTyrFrbPU4CX3ZURNfK5pzU-kbVdH-nwsRaePlGNwRZBe7J2HXsR4PsRhy
U2]."
If you're interested, visit my twice-a-month blog at the STRATMOR Group web
site
located at www.stratmorgroup.com
[http://r20.rs6.net/tn.jsp?llr=zy6u9cdab&et=1106312194052&s=8721&e=001M6pGSU
VzFrtuqmwQWA0OdZp4ch4_Gq8H0bPgOaGzrkDu19CBggiFAiInVFGcV31ZiMer8NfkbbqXtHfam0
SCXM2DZ2gNe_KRsWy8ZqsNeccd57BBkrZF4Q==]
. The current blog takes a look at near-term news for non-agency securities,
such
as jumbo residential loans. If you have both the time and inclination make a
comment
on what I have written, or on other comments so that folks can learn what's
going
on out there from the other readers.
Rob
(Check out
http://www.mortgagenewsdaily.com/channels/pipelinepress/default.aspx
[http://r20.rs6.net/tn.jsp?llr=zy6u9cdab&et=1106312194052&s=8721&e=001M6pGSU
VzFrt5P3dbbpHPhpHbrgOEWgsLXNVX-uJ628yfK1ibDtEPdlTFc7rYu6-pFvWvfOOAnuPnHKD9Rm
65Dlq7UVI6gV21OERvO_jaaBEWDAnHlgcSutoSaxDoHdLV3qvzVyRjM_np4stosPXUb3M4nzCaY4
QjLuBXxRELsTXET6oMRnmLSg==]
or www.TheBasisPoint.com/category/daily-basis
[http://r20.rs6.net/tn.jsp?llr=zy6u9cdab&et=1106312194052&s=8721&e=001M6pGSU
VzFrtRP1uGJ6Jji2SCIfCqCtcKdp4JTMeTrnJeTaC5bP3G8Q1x6ITUh2ssimNJJICPRgiEggHlC3
nHSWQ8jErpi22UB5dBYQCJrFw1YOJuRg7DHAmNWBaCjL4JbR1SYa94S-Qn-ZbJaUKEWA==].
For archived commentaries, go to www.robchrisman.com
[http://r20.rs6.net/tn.jsp?llr=zy6u9cdab&et=1106312194052&s=8721&e=001M6pGSU
VzFrvMcgg_D0nEdZ8bRgrUflpCq2XbSpGq2gmzXKmnW00fL67O0JID3Y6ZvNwLjsWUWr5TfP8Lmm
BZwEIIwH9hBiJhoKKdVvLW3J0PANM7I-lljg==].
Copyright 2011 Rob Chrisman. All rights reserved. Occasional paid notices
do appear.
This report or any portion hereof may not be reprinted, sold or
redistributed without
the written consent of Rob Chrisman.)
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