As previously noted, FSOC’s 2019 annual report for the first time paints nonbank mortgage origination and servicing with the systemic label from which numerous outcomes – all costly – may come.  Judging by the subsequent Calabria statement, next up is FSOC consideration of activity-and-practice designation, a move that could quickly lead to bank regulatory actions that redefine the nonbank business model unless or until Treasury and the banking agencies are satisfied with state, Ginnie, and FHFA constraints.

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