A high-profile Fed staff study adds to ongoing fears at Ginnie and FHFA about the growing role of non-bank mortgage sellers and servicers, providing additional detail on the post-crisis transformation of residential finance and the risks it poses.  The non-bank lesson is already learned at least to some extent as far as the GSE-reform bill is concerned – see our earlier analysis of the bill’s tough capital standards.  However, the bill’s status is at best uncertain even as FHA, Ginnie, and FHFA leadership are in flux.

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