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Loans are taking longer to originate these days. The best loan I have done in my career is a 20% loan-to-value loan to a borrower who makes $8 million per year and who has a 760 FICO score. It took six months, mostly because the underwriter was afraid that it was going to cost her her job because she might have missed something that would come back to bite later. The ex-employee of a BIG BANK said that one loan she did took over a year to fund.
I think that it is worthwhile to explore some of the reasons for this.
The fear factor
The most important is the fear factor that dominates lenders these days. To be sure, most lenders are merely “originators” of loans these days. 90 percent of loans are sold ultimately to Fannie Mae, Freddie Mac, or are FHA or VA loans. All of these entities are, in effect, operated by the Federal government.
Not all originators sell their loans directly to Fannie or Freddie. They are sold to an intermediary investor who, in turn, sells the loan to Fannie or Freddie. These intermediary lenders are, not so strangely, the exactly same institutions that dominate retail mortgage lending, Wells Fargo, BofA, Chase, Citicorp, and GMAC.
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During the 2005 to 2008 time period Fannie and Freddie were stupidly trying to “maintain market share,” and they correctly calculated that they could get more business if they lowered lending standards. Apparently, there was no thought of the potential higher default rate on those lower quality loans. We know the rest of the story.
But the latest chapter is that Fannie and Freddie are trying to get some of these lenders to buy back billions of dollars of loans from that period that went bad. As you might expect, that is making them quite jumpy, to say the least. BofA has paid of $5 billion to settle some but not all of these claims.
What this has caused among these lenders is the possibility that they might someday have to buy back loans they are originating today. Consequently, they want to make sure that the loans they are evaluating today are “squeaky clean.”
At this point you should understand that it is virtually impossible to do a “bad” loan today. We get an appraisal from a pristine system so we know values and we know what equity is. We get credit reports that are from a fool-proof system. In addition to what income documentation the borrowers provide, we get them to sign a Form 4506T what allows a lender to get almost immediate feedback on the last tax returns. What is left that could be a problem?
Next page: System overload »
Image: James West, via Flickr.com
System overload
Unfortunately, what is left is the trivia. So the entire mortgage processing system is bogged down in chasing irrelevant trivia. I’m going to give you some examples.
The Patriot Act requires that we get government issued identity papers, usually a driver’s license. It’s not like we are concerned about terrorists buying homes, OK? It’s just a rule that was initially started to keep drug dealers and the like from putting money in the banks under funny names. Someone said that it ought to apply to borrowers too, hence the procedure.
So a recent borrower’s license had on it his old address from 3 years ago. When you move, you tell the DMV but they don’t issue you a new license. The underwriter wanted an “explanation” letter on the address and I needed to get a property profile on that property to assure the lenders he didn’t still own it. Finally, his license expired last Saturday so we had to get a copy of the temporary license he got when he got his new one.
The new Good Faith Estimate, GFE, has very specific dates on the form. Not only that, there is no place on the form for the borrower to sign so that I can prove that I have it to him. That doesn’t really make much difference because the lender who is going to fund the loan also has to send him a GFE as well. To prove he got it, some lenders have a new form that basically says, “I got the GFE and I wish to proceed.”
Note that one requirement – when it comes time to lock in, if the APR on the loan is more than 1/8th percent UP or DOWN, it triggers a re-disclosure and a waiting period. The dates are, again, very important. I can assure you that somewhere, sometime, some lender is going to have to buy back a perfectly good loan because some of the dates were “inconsistent with the regulations” and the presumption is that the borrower was defrauded because disclosures were improperly prepared. Totally absurd! The list goes on and on and the costs go up and up.
As a parting shot, consider this question to ask lenders: every loan they funded was a good loan. If it was a good loan, why did you make it so difficult to get?
In a future article I want also to discuss “investor overlays” and the declining employee competence, two factors that make originating a loan no fun anymore.
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December 13, 2023
Mortgages