forbearance

14 11, 2022

DAILY111422

2022-11-14T17:00:05-05:00November 14th, 2022|2- Daily Briefing|

FSB Thinks 2020 Reg Relief Could Go, Stay – It All Depends

In conjunction with the G20 summit, the FSB has released a policy paper assessing the extent to which various pandemic-related regulatory forbearances should be continued.

FSB Reiterates Climate, Crypto, NBFI Plans

The FSB head’s letter to the G20 today reiterates all of the priorities expressed in its October letter to G20 finance ministers.

Regulatory Hearings to Address Last-Gasp 2022 Agenda, Position Panels for a Busy New Year

With GOP House and Democratic Senate control largely assured, this week’s hearings with Messrs. Barr, Gruenberg, Harper, and Hsu will illuminate not only current priorities – most notably what’s next for federal crypto law and rule – but also the very different priorities HFSC and Senate Banking will advance in the next Congress.

FRB-NY Staff: Big U.S. Banks Remain Extremely Resilient

In its latest assessment of the vulnerability of the fifty largest U.S. BHCs, Federal Reserve Bank of New York staff confirmed the overall rosy assessment of bank resilience in the Board’s latest financial-stability report (see Client Report SYSTEMIC94).

OCC Ramps Up Fair-Lending Enforcement

In remarks delivered for Acting Comptroller Hsu, Senior Deputy Comptroller for Bank Supervision Policy Grovetta Gardineer reiterated that ensuring fairness is a top OCC priority.

Gruenberg Finally Gets the Nod

Knowing now that he has secured Democratic Senate control into next year, President Biden today finally and formally nominated Acting FDIC Chairman Gruenberg to assume the chairmanship.

Daily111422.pdf

26 09, 2022

GSE-092622

2022-10-03T11:09:21-04:00September 26th, 2022|4- GSE Activity Report|

One Way Down

As will be evident in our forthcoming in-depth analysis, the CFPB’s fusillade last week on mortgage-finance could have far-reaching implications for the entire market based on how far it takes its new campaign for equitable housing finance and whether the market is willing to come along on at least some of the agency’s new ideas.  And, of course, the Bureau could well follow up an implicit threat to force new mortgage products if the industry proves unwilling to comply with its social-justice vision.  It will take months, if not years, to finalize many of the rules outlined in the RFI, but this schedule is subject to change without notice if the Bureau decides to rewrite mortgage finance by edict, not administrative process.  Indeed, new CFPB enforcement actions tackling refi-borrower risks seem imminent.  FHFA and/or HUD action to support or even mandate some of the CFPB’s ideas would also be radical redesign in one heck of a hurry.

GSE-092622.pdf

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22 09, 2022

DAILY092222

2022-09-26T15:10:10-04:00September 22nd, 2022|2- Daily Briefing|

CFPB Starts Mandatory Refi, Loan-Mod Redesign Project

Expanding its actions to increase consumer-finance innovation and competition, the CFPB today began an effort to increase refi accessibility as well as provide for automatic loan modifications.  The release reiterates Director Chopra’s assertions that rules prior to the Bureau’s new approach were unduly favorable to industry, especially when innovation is authorized only via no-objection letters, sandboxes, or similar agency actions.

Treasury Presses Open-End Bond Fund Rules

In remarks today on Treasury-market stability, Under-Secretary Liang focused on open-end corporate-bond funds.  Noting that these funds use Treasury securities for liquidity but lack stress resilience and thus caused the “cash for cash,” Ms. Liang strongly supported the SEC’s focus on open-end fund liquidity, pricing and resilience.

House Republicans Take New Tack to Constrain the CFPB

Joined by Republicans on the House Oversight Committee, HFSC’s GOP today continued its campaign against Rohit Chopra, giving the CFPB director only a week to provide them with an explanation of how many recent actions comply with the Supreme Court’s recent restrictions on administrative action.

Daily092222.pdf

22 08, 2022

GSE-082222

2023-01-04T10:56:18-05:00August 22nd, 2022|4- GSE Activity Report|

Forbear to Forget

A new Federal Reserve Bank of Cleveland study validates forbearance as a mortgage-market buffer, reinforcing the likelihood that policymakers and servicers will turn quickly to it if current mortgage-market conditions turn ugly under the combined stress of higher rates and slow to no growth. If bank regulators also reinstate regulatory forbearance on forborne loans, the regulatory-capital cost of higher-risk loans gets a nice counter-cyclical boost, perhaps encouraging banks to tread softly back into at least some of this sector if parallel calculations under the all-powerful stress capital buffer prove propitious.

GSE-082222.pdf

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