An SEC letter to CFOs pressing for buy-back and rescission disclosures – including those related to regulatory and litigation risk – puts more of a hammer in FHFA’s hand as it builds on the subpoena sent this summer to the biggest mortgage servicers.  Forcing a lot more transparency into this arena will lead to quicker recognition of likely claims by the GSEs, MIs and government agencies, especially in light of the SEC’s demand for forward-looking, rolling reserve estimates – assuming of course those on whom claims are made are willing or able to meet them.

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