Securitization and Systemic Risk
A new Fed staff study uses models to conclude that government-backed mortgage securitization exacerbates financial crises, contradicting conventional wisdom that – GSE blow-ups notwithstanding – properly-regulated GSEs create a liquid, diversified asset pool for an otherwise illiquid, risky asset class. However, our read of the study leads us to side with conventional wisdom.
Tackling Title
In a blog post today, Fannie quietly renews its quest for alternatives to traditional title insurance. The post focuses in general on closing costs, noting for example how regressive these are by citing cost differences of 13% for low-income first-time homebuyers than for all homebuyers on median closing costs as a percent of the home purchase price and 19% for non-low-income repeat homebuyers. Title insurance is discussed at length, with Fannie noting its efforts to allow homeowners to use lower-cost options as well as emphasizing the low risk of title claims due to real-estate data digitalization. The post does not go on to suggest that Fannie might simply omit a title-insurance requirement for at least first-time or LMI borrowers, but this seems to be the point.
OFR Sees Heightened Systemic Risk
Striking a considerably more somber note than the FRB (see Client Report SYSTEMIC97), OFR today concluded that systemic risk is elevated due to an upcoming economic slowdown, heightened inflation, and geopolitical risk and global conflict.
OCC Cracks Down on BNPL Finance
Reflecting continuing CFPB concerns about buy-now/pay-later finance, the OCC today sets new risk-management standards for federally-chartered entities in this arena.
HFSC Housing Subcommittee Revisits Housing Debate
Today’s HFSC Housing Subcommittee hearing largely followed the staff memo’s outlined political playbook, with Chairman Davidson (R-OH) calling for market-based solutions and Ranking Member Presley (D-MA) arguing that expanded subsidies are necessary alongside zoning reform to make housing affordable.
Fed Proposes Market-Risk Valuation Reporting
Readying disclosures for the market-risk capital rewrite (see FSM Report CAPITAL233), the Federal Reserve has proposed new reporting standards that would require covered banks to disclose valuations of their covered positions taking into account unearned credit spreads, close-out costs, early termination costs, investing and funding costs, liquidity, and model risk.
Fed Proposes New Liquidity Risk Reporting Standards
Reflecting growing fears that banks could not actually monetize HQLAs under stress as proved the case for Credit Suisse, the FRB is also proposing new reporting standards requiring covered companies to report on qualifying master netting agreement compliance with current liquidity-risk measurement standards.
A new FRB-NY study confirms that 83% of loans from 2000-2022 went to first-time homebuyers, compared to 56% for the GSEs and 57% for private lenders. FHA loans of course have very high LTVs and low scores, with scores improving after 2008 when the PLS market stopped adversely selected FHA even though over half of FHA loans still have scores under 680. FHA sustainability has varied based on these and other factors, but 21.8% of borrowers from 2011-2016 still lost their homes.
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FHA’s Mission and Mishaps
A new FRB-NY study confirms that 83% of loans from 2000-2022 went to first-time homebuyers, compared to 56% for the GSEs and 57% for private lenders. FHA loans of course have very high LTVs and low scores, with scores improving after 2008 when the PLS market stopped adversely selected FHA even though over half of FHA loans still have scores under 680. FHA sustainability has varied based on these and other factors, but 21.8% of borrowers from 2011-2016 still lost their homes.
An Advanced View of Regulatory Capital?
The most significant thing in FHFA’s final capital rule is not what is to be done, but what FHFA left out: ending the GSEs’ advanced-approach requirement. As a result, Fannie and Freddie can still use models for key calculations, a requirement that makes more sense for two complex organizations than it did for the regional banks also long subject to advanced-approach requirements even though the rules required them, like GSIBs, to hold the higher of the standardized or advanced approach.
More for Mortgages?
As our reports on the Senate and House hearings with bank regulators made clear, our prediction that the agencies would compromise on mortgage risk-based capital requirements will prove itself in the final standards. However, it’s far from clear if the compromise the agencies think will satisfy Congress will do much beyond directly addressing concerns that the proposal adversely affects LMI loans.
Spotting SPVs
As noted in our report earlier today, the Federal Reserve’s latest financial-stability report expresses deep misgivings about complex securitizations. This flies directly in the face of its recent decision to liberalize the capital treatment for credit-linked notes involving bankruptcy-remote SPVs, yet more evidence that the U.S. has a central bank of many silos that interact infrequently, if at all.
30-10 or Bust
With smaller lenders today joining MBA, NAR, and HomeBuilders’ campaign to squeeze the 30-10 spread, we take a look at the odds the White House, Fed, or Treasury will do as hoped. We think it more than possible that the PSPA could be revised with FHFA consent to allow the GSEs to hold more of their own MBS as a spread stabilizer; whether the GSEs will do so unless forced is another question given the considerable capital cost this would exert.
It’s Not Over…
Or maybe it is, but not everyone has heard. Earlier this week, Rep. Andrew Ogles (R-TN) introduced H. R. 5549 to require Treasury to give Congress a complete plan to end the GSEs’ conservatorship. Our forecast: don’t wait up. Our observation: it’s interesting that a conservative freshman hasn’t given up even though there’s no sign that his leadership has any interest reviving this idea. This is far too early and far too little to suggest a leading indicator to renewed Republican interest in tackling the GSEs now that Pat Toomey is gone from the Senate, but it’s noteworthy nonetheless.