Entries Tagged as 'Subprime Lending'

House Judiciary Committee Hearing Bankruptcy Cramdown Today

Today, the U.S. House of Representatives Committee on the Judiciary, Subcommittee on Commercial and Administrative Law holds a hearing on the “Growing Mortgage Foreclosure Crisis: Identifying Solutions and Dispelling Myths.”

Scheduled to testify are:

  • Hon. Jack Kemp
    Former Secretary
    U.S. Department of Housing and Urban Development
  • Wade Henderson, Esq.
    President and CEO
    Leadership Conference on Civil Rights
  • David G. Kittle, CMB
    Chairman-Elect
    Mortgage Bankers Association
  • Mark M. Zandi, Ph.D.
    Chief Economist
    Moody’s Economy.com, Inc.
  • Faith Schwartz
    Executive Director
    HOPE NOW Alliance
  • John Dodds
    Director
    Philadelphia Unemployment Project

Today’s Wall Street Journal (paid subscription required) carries an op-ed piece entitled A Mortgage Tweak We Don’t Need by Dick Armey.  Mr. Armey, Majority Leader of the U.S. House of Representatives from 1995 to 2001, argues that the proposed cram-down measures will necessarily impose substantial increased costs and other burdens on mortgage borrowers and is bad for consumers.

The Mortgage Bankers Association yesterday issued a press release, in which Mr. Kittle calls a recent report by the Center for Responsible Lending on loan modification and bankruptcy reform misleading.

In the words of the release:

By choosing to misread and misinterpret the existing data on subprime loans, officials at the Center for Responsible Lending have again demonstrated they are more interested in advancing their own legislative agenda than in having an honest debate about the real scope of the problem and how to help those most in need.

According to Moody’s, more than 50 percent of borrowers with subprime ARMs scheduled to reset in the first eight months of 2007 refinanced or otherwise paid off their loans prior to the rate reset. So more than half of those loans that CRL cites as at-risk will never see their rates reset. In fact, the bankruptcy changes CRL advocates for would actually make it harder for consumers to refinance out of their subprime loans because it would increase the cost of all new loans.

And CRL’s stubborn insistence on clinging to ‘loan modification’ as the only means by which a lender can help a borrower in trouble only serves to further mislead policymakers into overreaction. Repayment plans, forbearance and even short sales are all widely accepted ways of helping a consumer avoid foreclosure. And yet CRL ignores them, because including them would better demonstrate the vast efforts lenders make.

Mr. Kittle advises lawmakers to ignore the report as “more rhetoric than fact.”

Subprime Problem - White House Hints at a Real Solution

The Conference of State Bank Supervisors picked up on a little reported, but extremely important, announcement from the White House yesterday afternoon. 

The announcement discusses a badly needed initiative that, if properly advanced, could go far to providing a long-term, real economic solution to problems that have arisen in the subprime market.  It could also help alleviate issues arising with payday lending, bounced checks, other uncollectible debt and bankruptcies.

The solution is educating broad swaths of Americans in basic personal finance and economics.  Of course, this process will take years, and it is far from clear whether the Bush administration’s efforts will have any sustained effects or even if the program touted is a good program.  Also, many issues demand immediate attention and hard work. 

One thing is clear, however, neglecting this long term solution will only result in continual repeats of the current problems.

The pertinent part of the announcement: 

THE PRESIDENT: I appreciate members of my Cabinet joining me today with some of our citizens who care about the future of our country and are willing to do something about it. Earlier today I signed an executive order establishing the President’s Advisory Council on Financial Literacy. I have asked people from the business world, the faith world, the non-profit world, to join this council in order to come up with recommendations as to how to better educate people from all walks of life about matters pertaining to their finances and their future.

Chuck Schwab is the chairman of this group, and John Hope Bryant is the vice-chair.  These two men have agreed to take time to take the lead, and I appreciate it.

You know, it’s interesting that if we want America to be as hopeful a place as it can be, we want people owning assets. We want people investing. We want people owning homes. But oftentimes, to be able to do so requires literacy when it comes to financial matters. And sometimes people just simply don’t know what they’re looking at and reading. And it can lead to personal financial crisis, and that personal financial crisis, if accumulated to too many folks, hurts our country.

One of the issues that many of our folks are facing now are these sub-prime mortgages. I just wonder how many people, when they bought a sub-prime mortgage, knew what they were getting into: The low interest rates sounded very attractive, and all of a sudden, that contract kicks in and people are paying high interest rates. One of the missions is to make sure that when somebody gets a financial instrument they know what they’re getting into, they know what they’re buying, they understand.

We want people to own assets; we want people to be able to manage their assets. We want people to understand basic financial concepts, and how credit cards work and how credit scores affect you, how you can benefit from a savings account or a bank account. That’s what we want. And this group of citizens has taken the lead, and I really thank them — thank you a lot.

Cleveland Sues Lenders for Nuisance

In another example of how costly state and local hyper-regulation of the mortgage banking business can be, the City of Cleveland announced that it was suing “21 Wall Street companies who financed and cultivated the sub-prime market.” 

 What is the legal basis for suing these 21 companies whose apparent transgression was giving money to subprime borrowers (i.e., people who had previously shown a lack of fiscal discipline by not paying their bills on time)?  The alleged offense is (drum roll) Public Nuisance.   This is better than fiction. 

In the words of the City:

Today, Mayor Frank Jackson confronted the foreclosure crisis at its very core; along with his Law Director Lawrence Triozzi, he announced that the City of Cleveland is seeking damages from some 21 Wall Street companies who financed and cultivated the sub-prime market.  The defendants violated the Ohio public nuisance law which is what the City of Cleveland will use to seek damages.

“Cities can rebound, however it is extremely costly to do so given that declining tax revenues are part of the fallout of foreclosures,” said Mayor Jackson.

Public nuisance is a longstanding, well-established legal concept.  It allows recovery for circumstances created by the defendant that interfere with the public’s “rights and interests”.  The unscrupulous lending practices that are part of the sub-prime market have devastated Cleveland neighborhoods which clearly demonstrate a public nuisance.

“There has been a national conversation about how the banks recover from the foreclosure crisis but no one is talking about what should be done to support Cities who have the challenge of managing this situation,” said Triozzi. 

In the words of one commenter, “I don’t know whether to laugh or cry.” 

The point is a number of regulators and “enforcers” are pointing at lenders and saying you should not have made these loans.  The fact of the matter is lots of lenders in a very broad and diverse marketplace gave lots of borrowers lots of money.   A relatively small percentage of these borrowers are not paying that money back.  “Enforcers” like Cleveland therefore claim that Lenders should not have made these loans. 

A 5 percent rate of people failing to pay their mortgages on time, however, should not result in the other 95 percent of homebuyers being shut out of the market.  That would be far more than a nuisance - that would be a simple outrage.

Paulson Recommends Expanding Efforts to Prime Borrowers

Meeting with leaders on Wall Street, Treasury Secretary Henry M. Paulson yesterday proposed that the HOPE NOW Alliance expand its efforts to assist borrowers who took out adjustable rate mortgage loans, even if those borrowers were not “subprime.”

  Mr. Paulson stated:

After years of unsustainable price appreciation and lax lending practices, a housing correction was inevitable and necessary. That correction is underway. Over the next two years, we also face an unprecedented wave of 1.8 million subprime mortgage resets, raising the potential of a market failure. Because the industry does not have the capacity to manage this volume, without action, unnecessary foreclosures would result.

To meet this challenge, this Administration ?without committing any taxpayer money ?helped foster an industry-wide effort to prevent this market failure. By preventing avoidable foreclosures, we will safeguard neighborhoods and communities, and fulfill our primary responsibility of protecting the broader U.S. economy. However, let me be clear: there is no single or simple solution that will undo the excesses of the last few years.

Mr. Paulson went on to explain how the HOPE NOW Alliance strives to avoid “preventable” foreclosures.  The Alliance takes a three pronged approach.

First, the alliance is aggressively reaching out to homeowners who are or will be struggling with their mortgages.

Second, industry and government are developing new mortgage products that will enable more people to stay in their homes.

Third, the industry has developed a systematic streamlining process that replicates normal market actions to fast-track borrowers towards a solution, when possible. The industry needs this streamlining to manage the unprecedented volume of resets that cannot be addressed through individual, loan-by-loan negotiations.

Mr. Paulson noted that critics of this third prong assert that it abrogates contracts with investors.   To the contrary, he argued, servicers fulfill their contractual obligations by pursuing “all loss-mitigation options when it is in the best interest of investors,” as their contracts typically provide.  Investors participate in this approach because they recognize the benefits of avoiding preventable foreclosures.

According to Mr. Paulson, the HOPE NOW Alliance now represents more than 90 percent of the subprime servicing market, including the 20 largest subprime servicers.  The Alliance also involves major non-profit mortgage counseling organizations, trade associations and investors.

Mr. Paulson pointed out that limiting the damage was not an easy or simple task, but the Alliance participants had been hard at work over the last several months.

The first step has been to contact troubled borrowers. In its first two months, the HOPE NOW alliance sent over 450,000 letters to at-risk borrowers who had not previously contacted their servicers. Servicers estimate that, as a result of this effort, approximately 10 percent, or 45,000 homeowners, have called their servicers to see if foreclosure can be avoided.

Servicers are also moving to quickly implement the framework for streamlined refinancings and modifications announced by the American Securitization Forum (ASF) ?which represents mortgage market participants, including many of the largest investors. This is not simple; there are legal, accounting and operational considerations. Servicing departments need to link with mortgage originators; this can be difficult for independent servicers. And they must fully implement connections to FHA. Servicers are collaborating to share best practices so all borrowers and investors may benefit from the ASF framework, regardless of who their servicer happens to be.

Last Friday over 20 HOPE NOW alliance servicers gathered to work through implementation details, and will continue an intense pace in order to establish the necessary infrastructure and processes. We expect most servicers to begin fast-tracking borrowers in the next few weeks.

The Treasury continues to monitor the matter, and work with the various participants to see that the Alliance best achieves its goals without a taxpayer bailout. 

Then, in a somewhat subtle hint, Mr. Paulson suggested the Alliance also assist non-prime borrowers:

We need to see all servicers reporting results to HOPE NOW to measure effectiveness and then make adjustments as needed. This may include using elements of a systematic approach for adjustable-rate mortgages other than subprime if it will benefit homeowners and investors.

This appears to be the first official acknowledgement by the Treasury that the problems facing subprime borrowers also challenge Alt-A and prime borrowers. 

The problem stems in many ways from inflated real estate prices, low interest rates and lax lending standards.  Subprime generally refers to borrowers with low credit scores. 

But aggressive borrowing was not limited to low credit score applicants in recent years.  Across the country, millions of homeowners stretched to buy expensive homes over the last several years while rates were low and prices high.  Frequently, the easiest way to do this was to take out an ARM loan with a low introductory rate.  Those rates reset whether the borrower has high or low credit ratings.  If the borrower lacks the cash to make the monthly payments, there will be problems.

For its own part, the industry quickly backed Mr. Paulson’s suggestion.  Today’s Wall Street Journal (paid subscription required) reported that the American Securitization Forum: 

which represents investors who have bought mortgage-backed securities. Without the investors’ approval, mortgage-servicing companies that collect the checks from borrowers run the risk of litigation if they relax the loan terms.

“To the extent that servicers can develop and apply systematic approaches to assist them in their efforts to identify appropriate loss mitigation outcomes for adjustable rate mortgages other than subprime, we support those efforts,” George Miller, the group’s executive director, said in a statement released after Mr. Paulson’s speech.

While imperfect, the investors understand that an approach that limits their losses makes the most sense. 

Naturally, this approach will not sway those who have called for bailouts.  The National Community Reinvestment Coalition, for example, responded with a simple statement suggesting the culprit was not high prices and excessive borrowing, but rather “unfair and deceptive lending practices.”   A number of groups, and some presidential candidates, have called for forced permanent extensions of low teaser rates, taxpayer funded bailouts, and other heavy handed approaches. 

For my own part, I’m wishing I had not paid off my ARM so quickly. 

Mortgage Bankers - Energize Your Industry

The year 2007 was not kind to the mortgage banking industry.  A Reuters story today reported a MortgageDaily.com study showed more than 86,000 jobs lost in the mortgage industry last year, nearly 16,000 in California.  The Mortgage Lender Implode-O-Meter lists 211 companies that closed last year.  MortgageDaily.com’s “Mortgage Graveyard” lists 147 companies failed or went bankrupt in 2007, compared with just 18 in 2006.

Foreclosures are way up.  Losses are way up.  Legislators, regulators and investors threaten to storm the castle doorts.  (See earlier posts regarding pending legislation and Massachusetts Attorney General’s Office).

In such times, it becomes more important than ever to become active supporters of our mortgage banking industry.  One way to become active, protect the industry and meet some great people is to become active in the Future Leaders Program run by the Mortgage Bankers Association

As indicated on the MBA’s website, the Future Leaders Program:

is dedicated to identifying and cultivating the next generation of industry leaders by delivering a comprehensive leadership training experience for selected participants through three events offered throughout the year.

As a member of the 2007 Future Leaders group, I can assure that the program is well worth the effort.  This year, participation is probably more important than any time in recent history.  If anyone would like to discuss the program in confidence, I would be glad to do so.

Dodd Exits Presidential Race; Focus Turns to Lenders

Placing sixth in the Iowa caucases, Senator Christopher Dodd abandoned his bid for Democratic Presidential nominee.  Personally, this was somewhat of a surprise to me after what I thought was a reasonably strong showing in the November Democratic Debates.  The results in Iowa surprised many people, however, and the race has tightened signficantly. 

Senator Dodd, for now, can turn his full attention back to his regular duties as Chairman of the Senate Committee on Banking, Housing, and Urban Affairs.  That presents risk for the lending community. 

As you know, the U.S. House has already passed a bill aimed at curbing alleged abuses by lenders and brokers.  The bill, “The Mortgage Reform and Anti-Predatory Lending Act of 2007, H.R. 3915,” presents a number of serious problems for the mortgage banking industry.  For example, the Committee’s press release notes the House Bill imposes on loan originators a so-called Federal “Duty of Care” that requires the originators to present consumer with “appropriate” mortgage loans, ensure the consumer has a “reasonable ability to repay,” ensures the consumer receives a “net tangible benefit,” ensures that the loan lacks “predatory characteristics” and prohibits “steering.”  You know, the kinds of terms that can make a plaintiff’s bar salivate.

Not to be outdone, Senator Dodd on December 12, 2007 introduced his own bill, “The Homeownership Preservation and Protection Act of 2007.”  The Senate Bill contains similarly troublesome provisions.  For example, among other things, the bill:

  • lowers the thresholds for a loan qualifying as a High Cost Loan;
  • requires that each mortgage originator “act in good faith and with fair dealing in any transaction, practice, or course of business in connection with originating any home mortgage loan,
  • requires that each mortgage originator “make reasonable efforts to secure a home mortgage loan that is appropriately advantageous to the borrower, considering all the circumstances, including the product type, rates, charges, and repayment terms.”
  • requires that each mortgage broker “act in the best interest of the borrower and the “utmost good faith toward the borrower” and refrain from compromising the rights or interests of the borrower in favor of the rights or interests of another,
  • prohibits a mortgage originator from steering, counseling or directing a consumer to a loan with rates, charges, principal amount, or prepayment terms that are “more costly than that for which the consumer qualifies,” and
  • prohibits prepayment penalties on certain types of loans and certain yield spread premiums.

Senator Dodd’s press release regarding the proposed bill attaches a list of 11 individuals supporting the bill: 

  • Martin Eakes, CEO, Center for Responsible Lending
  • Hilary O. Shelton, Director, NAACP Washington Bureau
  • David Sloan, Director of Government Relations and Advocacy, AARP
  • Iowa Attorney General, Tom Miller
  • Maude Hurd, ACORN National President
  • Allen Fishbein, Director of Housing and Credit Policy, Consumer Federation of America
  • Shanna Smith, President & CEO, National Fair Housing Alliance
  • John Taylor, President & CEO, National Community Reinvestment Coalition
  • Wade Henderson, President, Leadership Conference on Civil Rights
  • Alys Cohen, Staff Attorney, National Consumer Law Center
  • Don Borut, Executive Director, National League of Cities

Funny, I see no one listed from the housing finance industry:  no lenders, no brokers, no title companies, no realtors, no appraisers, no mortgage insurers.  Maybe they are still trying to figure out what these words actually mean. 

The Mortgage Bankers Association did issue a press release stating that the bill had:

several provisions that concern us deeply.   Senator Dodd’s bill does not provide a uniform national standard to protect consumers from predatory lending, a step we feel is necessary to ensure a smooth and efficient marketplace.  Further, we are troubled by the bill’s ‘duty of care’ and assignee liability requirements.

Stay tuned . . .

WSJ Gets It Wrong on Subprime Lobbying

Today’s top story in the Wall Street Journal (paid subscription required) criticized the federal and state lobbying efforts of subprime mortgage companies in recent years.  In particular, the article singles out Ameriquest. 

Working with a husband-and-wife team of Washington lobbyists, [Ameriquest] handed out more than $20 million in political donations and played a big role in persuading legislators in New Jersey and Georgia to relax tough new laws. Those victories, in turn, helped blunt efforts by other states to crack down on reckless lending, critics of the industry contend.

The article goes on to say:

Data . . . show[s] that from 2002 through 2006, Ameriquest, its executives and their spouses and business associates donated at least $20.5 million to state and federal political groups. In comparison, over the same time period, Countrywide Financial, another large subprime lender, gave about $2 million in campaign gifts, and spent an additional $6.7 million lobbying in Washington, records indicate. 

The article mentions a number of banks, other lenders and trade groups that also engaged in lobbying efforts. 

I am a fan of the WSJ.  It is the best written, most informative, most pertinent newspaper printed in the US today.  But this particular article shoots for headline glamor, missing the bigger story.  

The article is riddled with fallacies.  I note only a couple.  The article indicates that a primary focus of these lobbying efforts was to “roll back” state laws on so-called “predatory lending.” Presumably, the article is suggesting the goal was to enable subprime lenders to engage in predatory lending activities.  The article is not clear.  However, the banks and certain lenders referenced are not subprime lenders, and certainly are not engaged in predatory lending.  In addition, the trade groups represent a much wider member base than subprime.  Moreover, the banks mentioned are not even subject to most state predatory lending laws due to federal preemption.  The WSJ seems to confuse predatory lending with subprime lending the same way many far less sophisticated articles do.  It should know better.

Further, the issue is not any voracious desire by lenders to engage in predatory activities.  The issue is that lenders must comply with numerous requirements imposed by the varying states, including more than 30 separate state “predatory lending” laws.  Even cities and municipalities have jumped on board, adopting their own local predatory lending provisions.  (At least the states shot down most of these provisions as stepping on the states’ own toes.) 

Rampant regulation in this area is out of hand.  Good lenders pay lots of money every year to do their utmost best to comply with these numerous burdensome, ambiguous and often inconsistent laws.  A good friend of mine tells me that Mavent Inc., a top-notch compliance software company providing compliance assistance to the industry helps lenders check for compliance with over 300 applicable laws.  300 laws!!!

Who do you think bears the cost of complying with all those laws?  It ain’t Santa Claus.

Nevertheless, the parties drafting bills circulating in Congress right now have rejected uniform national standards on predatory lending.  Instead, these bills would prefer the status quo - let every state come up with its own mongrel breed of predatory lending law.  Let the lenders figure it out.  Let the borrowers bear the cost.

That approach may be good for the economic future of my law firm, but it is not good for borrowers.