by Tanta on 1/24/2008 08:56:00 AM

Raising the conforming limit to $625,000. Because other kinds of stupidity take too long, I guess. Via Alex Stenback:

"Sources in the House, the Senate, and the White House are all indicating today that a tentative consensus has been reached that the economic stimulus bill that Congress will send to the President will include much of the FHA Reform Legislation including raising the FHA loan limit max to match the FHA conforming limit AND a one year raise of the conforming limit to $625,000 with the possibility of an additional one year extension at expiration. All sources also indicate Congress will deliver the bill to the President before their break in mid-February and that it should be signed by the end of February. Obviously this is not "done" but all of the sources I am using are very close to the action. This would mean that we could see at least the loan limit portions of the legislation we are hoping for within the next 6 weeks."

I can only hope Alex's source is drinking cough syrup, because while this is not the dumbest thing I have ever heard of--I work in the mortgage business, the thresholds are very high--it is quite close.

by Tanta on 1/11/2008 10:16:00 AM

What happens when a reporter straps on a decent-sized pack of skepticism about a trade association's PRs and picks up the phone. It's like so totally cool.

Floyd "Maybe This Isn't Just Subprime" Norris in the New York Times:

And now the banks are begging the accounting rule makers to allow them to ignore a rule that has been on the books for almost 15 years. They explain that they never had any idea that they would have to restructure a lot of home mortgages, and thus had no reason to develop systems to deal with the accounting for such restructurings.

“No one anticipated a day when potentially hundreds of thousands of residential mortgage loans would be modified,” said Alison Utermohlen, an official of the Mortgage Bankers Association who has led the effort to get the accounting rules relaxed.

She said many members of the association did not have computer systems adequate to comply with the rule, but she did not identify any specific banks. . . .

The accounting rule in question, Financial Accounting Standard 114, was adopted in 1993. Lynn E. Turner, a former chief accountant of the Securities and Exchange Commission, recalls that it was enacted because of abuses by financial institutions during the savings and loan debacle. Under the old rule, banks could avoid reporting losses so long as they expected to get the principal back eventually, even if the borrower did not have to pay interest on the restructured loan. The rule put an end to that.

Or at least it put an end to it for most types of loans. These banks live with F.A.S. 114 for their commercial mortgages and corporate loans, but according to Ms. Utermohlen, they don’t have systems in place to do the calculations for large numbers of restructured residential mortgage loans.

The calculations, it turns out, are not that complicated. You could do them with a decent financial calculator, or an Excel spreadsheet. But the banks argue that would take too much effort, given the volume of loans likely to be restructured. “This would be extremely time-consuming and would likely involve additional staff dedicated to this purpose,” Ms. Utermohlen said in a letter to the Financial Accounting Standards Board this week.

Will the banks win this argument? It appears to be one that they want to win without having to actually admit that any specific bank has a problem at all. I called five members of the Mortgage Bankers Association that are represented on the committee that Ms. Utermohlen said she worked with: Citigroup, JPMorgan Chase, Bank of America, Countrywide Financial and Washington Mutual. Countrywide said that its computer systems were adequate to comply with F.A.S. 114, but that it felt it would be “less burdensome from an operational standpoint” if the rule could be ignored. None of the other four told me whether their systems were adequate.

Thanks, Floyd, for joining the team. Whenever they're going out of their way to look stupid ("we have no one on staff who can actually use Excel"), the pea is under the other shell. And yes, it is always worth asking why we give bank charters to people who can't discount a cash flow with both hands and a flashlight.

by Tanta on 12/31/2007 07:01:00 AM

It's shocking. Via naked capitalism, this jewel from the WSJ on subprime lender-sponsored lobbying efforts against predatory lending regulation:

Washington lobbyist Wright Andrews and his wife, Lisa, coordinated much of the industry's lobbying. Mr. Andrews's firm, Butera & Andrews, collected at least $4 million in fees from the subprime industry from 2002 through 2006, congressional lobbying reports indicate. Mr. Andrews didn't represent Ameriquest directly. He ran three different subprime-industry trade groups: the National Home Equity Mortgage Association, of which Ameriquest was a member; the Coalition for Fair and Affordable Lending, which spent $6.3 million lobbying against state laws before it dissolved earlier this year, according to federal filings; and the Responsible Mortgage Lending Coalition.

In 2003, Lisa Andrews was appointed senior vice president for government affairs at Ameriquest. Her public-relations firm, Washington Communications Group Inc., claims credit on its Web site for coordinating the industry's victory in New Jersey, as well as its overall strategy at the state level. Ms. Andrews left Ameriquest in 2005 and returned to her firm. . . .

In the wake of the collapse of the subprime market, Mr. Andrews's subprime lobbying business has withered. The three trade groups he ran are gone, and most of his subprime clients have stopped lobbying.

"I certainly was not aware of the degree to which many in the industry clearly failed to follow proper underwriting standards -- the standards which they represented they were following to those of us who were lobbying," Mr. Andrews says.

Here's a hint, Mr. Andrews. When a regulation is proposed that says lenders should adopt a certain underwriting standard, and the industry responds by saying "we already do it that way," and then pays you $4 million to stop that regulation from being enacted, you actually have some reason to believe they're pulling your leg. No, really.

by Tanta on 12/21/2007 09:55:00 AM

With a curtsey to sunsetbeachguy, we stare in wonder at an interview with the Treasury Secretary in the LAT.

On disclosures:

The key is to get the balance right and not go so far that you cut off credit and make the situation worse. The Fed has also been looking at disclosure. I think when you look at the mortgage area, it's almost a caricature of what you see in other areas. You've got pages and pages of disclosure, which doesn't mean you're getting the people good information that they can understand. It's sort of, "Everybody cover their rear end," protect themselves legally. But, I've made the case several times, with all the disclosure there should be one simple page signed by the lender and the borrower that says, "Your monthly payment is x and it could be as high as y in a couple of years." The Fed I know has done some real consumer research on this.

I also have done some real research on this. I have found that when you prepare a simple, one-page document that says, "Your monthly payment is x and it could be as high as y in a couple of years, and you can't afford that, which is why we are denying your application for credit," you call it an "Adverse Action Notice" instead of a "Disclosure." But that kind of runs into that "cutting off credit" problem.

On interests, best:

And the way I think about it is this: that historically when a homebuyer, homeowner has a problem, a default's clearly not in the homeowner's interest. And it's clearly not in the lender's interest. It's very costly; defaults are very costly. So in a normal world the two sides come together and they strike a deal. Today we're dealing with two factors that make this more difficult. First, as you know, the institution or company that made the mortgage no longer holds it. It's spread all around the world with investors. That creates a cumbersome, complex decision-making process. It's one that can be dealt with when you've got home prices rising or you've got a stable mortgage market.

Historically, homeowners had a down payment invested in the property; also, historically homeowners who defaulted knew they'd have a hard time getting credit again in the future. Having removed the downpayment and minimal credit standards, there isn't much "cost" to default for a lot of people. Furthermore, if a default is costly to the "lender," then it is surely costly to whoever the "lender" is today. Why a transfer of servicing rights would, in and of itself, remove the incentive for working out loans is still kind of hard to see. But, as Paulson notes, this incentive failure can be responsibly managed when defaults are not costly. We pay this guy with tax dollars.

The whole interview goes on for a lot longer, but I can't take any more of this. You all will have to take it apart in the comments.

by Tanta on 12/14/2007 10:50:00 AM

BusinessWeek sums it up: "Dog Days at Cerberus."

Here's one for the Things You Have To Read A Couple of Times At Least To Assure Yourself That It's Not Just You File:

Now, say sources close to Cerberus, the $26 billion firm has slowed its pace of dealmaking with the credit crunch in full force. It's also focusing more rigorously on the troubled holdings in its portfolio—some of which may have blindsided the firm. The situation has prompted concern that Cerberus' returns may suffer. This comes at a time when all players are under pressure. "Industry returns have been extraordinary, 20% to 30% a year," says Katharina Lichtner, managing director of the private equity advisory firm Capital Dynamics. "Returns will come down, revert to a more normal 16%."

And what kind of socially redeeming value will Cerberus be adding to the mortgage biz for that perfectly normal 16%?

It's unclear just how much work it will take to fix GMAC, the financing arm of General Motors (GM). A Cerberus-led group paid $14 billion for a 51% stake in September, 2006. Cerberus wasn't exactly an industry newcomer. It had a front row seat at the subprime show with Aegis Mortgage, a lender it took control of in 1996. Yet Cerberus jumped into GMAC at exactly the wrong moment. Price defends the move: "There was one time to buy GMAC. We wanted it and took action."

The short story? Aegis filed for bankruptcy in August, and GMAC's mortgage group ResCap has been bleeding red ink. Cerberus watched GMAC continue to make subprime loans in the first quarter but has since reined it in. It wasn't fast enough to prevent the pain. ResCap has lost $3.4 billion so far this year, forcing GMAC to pump $2 billion into the business to help it survive the mortgage mess. And Lehman Brothers analyst Brian Johnson forecasts an additional $1.3 billion hit this quarter and $600 million in 2008. "I don't think anyone is panicked," says one Cerberus insider. But "we sure as hell didn't expect GMAC to be what it turned out to be."

Those problems may put a kink in the firm's strategy. Cerberus, which also owns 80.1% of struggling automaker Chrysler, wants to merge the lending operations of both companies. By doing so, it could reap massive savings on back office and loan processing operations, boosting returns at both GMAC and Chrysler.

Cut back office at a mortgage servicer. Put people who can service car loans in charge of mortgage loans. That's exactly what we need right now. Dog days at Cerberus, or just doghouse for the rest of us?

Let me just observe that GMAC's mortgage servicing unit was already pretty "stripped down" in its heyday. That was its business model: cheap servicing. I can't wait to see what happens when you make it cheaper.

by Tanta on 12/12/2007 09:30:00 AM

The Wall Street Journal is troubled by Fannie Mae's recent imposition of a 25 bps "adverse market fee" for new mortgage production. "Mortgage Pain Hits Prudent Borrowers":

Fannie Mae, the giant government-sponsored mortgage investor, last week raised costs for many borrowers by quietly adding a 0.25% up-front charge on all new mortgages that it buys or guarantees. On a $400,000 mortgage, that would mean an extra $1,000 in fees, almost certain to be passed on to the consumer. Freddie Mac, the other big government-sponsored mortgage investor, is expected to impose a similar fee soon, according to a person familiar with the situation.
...
In a statement, Fannie said the new fee is needed "to ensure that what we charge aligns with the risk we bear." The National Association of Home Builders labeled the fee "a broad tax on homeownership." More than 40% of all mortgages outstanding are owned or guaranteed by Fannie or Freddie.

The fee is the latest in a series of moves by Fannie and Freddie that raise the cost of credit for some borrowers. Late last month, they imposed surcharges that affect mortgage borrowers who have credit scores below 680, on a standard scale of 300 to 850, and who are borrowing more than 70% of a property's value. For example, someone with a credit score of 650 would pay a surcharge of 1.25% of the loan amount for a mortgage to be sold to Fannie. On a $300,000 loan, that would mean extra fees of $3,750. The fee could be paid in cash or in the form of a higher interest rate than
would normally apply.

Fannie also is raising down-payment requirements for loans it purchases or guarantees in places where house prices are falling, which by some measures is most of the country. In these declining markets, lenders will need to cut by five percentage points the maximum percentage of the home's estimated value that can be financed. For instance, for types of loans that Fannie normally would allow to cover up to 100% of the estimated value, the ceiling now is 95% in declining markets.

"A tax on homeownership." I swear, if the National Association of Builders didn't exist, I'd have to invent them. For comic relief. Ditto with "a higher interest rate than would normally apply."

Here's the deal: if you are taking out a mortgage--any mortgage--in a period of time in which home prices are rapidly falling, the financial future of lenders and builders is uncertain, and bailouts are already on the table, you may wish to call yourself "prudent" because you're getting a conforming fixed and your FICO score is better than those subprime people's. You may, therefore, feel sorry for yourself because you'll pay that extra quarter.

Or, you can wonder if maybe you should wait that extra half-hour after lunch before entering the swimming pool. Whatever. I'd like to hear the case for the GSEs backing off on fees right now.

In the interests of maximum nerdage, I'd also like to point out that the "no maximum financing in a declining market" rule that is mentioned here is not "new." It has always been the rule. Fannie and Freddie are taking the opportunity presented to them by current events to remind everyone that it is still on the books. Some people may think it's new, but some people think a "declining market" is, well, new. Unheard of. Not normal, you might say.

We should note that this rule does not simply change a 100% maximum to a 95% maximum. There are many maximum LTVs, depending on occupancy, purpose, FICO, property type, loan type (fixed versus ARM), and so on. So there are those 90% cash-outs that will be 85% cash-outs, and those 80% multi-unit loans that will be 75%. Cue more howling from the "prudent."

by Tanta on 11/21/2007 09:20:00 AM

I see you're coming around to a view of the housing and mortgage mess that has a clear reality bias. You're not there yet, but the trend is inspiring. I want you to know that I'm from The Blogs and I'm here to help you.

First things first: why have mortgage lenders worked out troubled loans ever since the dawn of mortgage lending? Because lenders do what lenders do: seek maximum profits. If a loan was supposed to earn you a dollar, but isn't earning you anything because the borrower is not paying, and you have the choice of restructuring, and getting, say, 90 cents, or foreclosing, and getting, say, 70 cents, you restructure. It is possible that, end of the day, you really get 91 cents instead of 90 cents if you cloak it in fine-sounding rhetoric about keeping The Dream Alive and helping borrowers stay in their homes and stuff. (It costs maybe a penny to write boilerplate PRs like that; you get two cents in benefits from Happy Regulators; it nets out.)

How does this get complicated? Well, traditionally, one had to be able to say, with some reasonable degree of certainty, what the cost impact was of the two options. That involved both modeling--looking at your historical experience as well as putting together a complex calculation of all the overt and hidden expenses and recoveries of each situation--and individual loan examination. It never helped you to say that "loans of this type should behave this way." That's what you said when you made them originally. At this point, you have a loan that is refusing to behave the way loans of its type are "supposed to" behave. You just have to break down and look at the borrower, the property, and the overall situation, to see if this is possibly a 90 center or inevitably a 70 center.

That requires people with skills. Enough people with skills to look at a lot of delinquent or about-to-be deliquent loans fast enough to not miss your window of opportunity on that 90 cents. Time is money in this business.

The industry is telling you right now that they just don't have enough people with the right skills to be able to wade through all the problem (or potential problem) loans fast enough to make the workout/foreclose decision. There are two reasons for this. The first is inevitable: no one runs a servicing operation with that many extra people sitting around waiting for a mortgage crisis. The second is not inevitable but is surely predictable: once the crisis happens, lenders start laying off, not beefing up, because crisis means earnings are down and you know what that means. I'm guessing that you had some experience with that kind of issue at Goldman. Plus the whole thing is complicated by these complicated securities we cheerfully put these loans in, that now have a bunch of complicated rules for getting them out. You know how securities lawyers bill out, don't you?

This means that the industry cannot do what it needs to do to defend itself. It will continue to take 70 cents instead of 90 cents, because it does not have the resources to commit to this problem, or because if it did commit those resources, the extra cost of staffing up and training and recruiting and so on would make the 90 cents scenario no longer achievable. Eventually the recoveries either converge--it's just as expensive to work out as it is to foreclose--or they don't, but only because the RE market is diving faster than salaries for workout specialists are improving, so that you end up with the choice of 70 cents or 50 cents, then the choice of 50 cents or 30 cents, down to wherever this has to go to sort itself out. Equilibrium in the housing market or servicer bankruptcy, whichever comes first.

Meanwhile, of course, the intangible returns--the credit we get for pretending that this is about Helping the Poor or being Heroes to Homeowners--do tend to inflate. That's the hallmark of a first-class economic crisis. However, on the level of nice rhetoric they don't inflate enough to cover what the industry is spending. Concrete bennies have to be put on the table. Regulatory relief. Fun with reserve and capital calculations. Approval of mergers and acquisitions. You know the drill. This is about maximizing profit. You are going to have to do something that makes this profitable, if you're going to expect lenders to do it on a large scale. Your job, of course, will be to write the PR that says that all this "regulatory relief" to for-profit banks and mortgage companies is all about Helping the Poor and being Heroes to Homeowners. I suspect you're up to that task. There is no shortage of PR-writers in this administration.

All that, of course, is about the historical or traditional approach to workouts. We are, you know, in the aftermath of a historically unprecedented binge of making loans to people whose creditworthiness, capacity, and collateral were, shall we say, not the issue. We can, of course, apply good old-fashioned time-tested methods of analysis of these loans now, after the fact, to see if they qualify for a modification. It will inescapably have an air of ludicrousness about the entire process. I can't help you with that, buddy.

Or, we can process the workouts the same way we processed the original loans: fast and cheap, with lowest-common-denominator thresholds for approval that really don't depend on an honest evaluation of the cost/benefit compared to foreclosure. You have to admit that this would have a charming kind of "fighting fire with fire" quality to it. You'd get some big time bad press here. But if the point is to allow servicers to workout loans without having to spend any money--hiring those workout specialists who know how to examine the loan, compare all the costs, and make a defensible call--this plan has Genius. It's rather like that earlier plan we had for making mortgages to every conscious person in America without having to mess with nonsense like documentation and underwriters and stuff.

All that said, though, it does seem like you might want to be kind of cautious about how many goodies you put on the regulatory table in order to get the lenders to play ball. I for one am not sure you can afford to cover all the checks your mouth is writing any more than the lenders can. It sounds to me like you probably need to hire a bunch of regulatory relief workout specialists who can put some dollars and cents on your options here.

I must say I'm enjoying having you a few inches closer to the reality-based community. I hold hopes that someday you and The Blogs will actually inhabit the same economic planet. That would be like so totally cool.

Thank you for your time and attention to this matter.

Tanta

by Tanta on 11/07/2007 01:08:00 PM

Because the color of someone's tie says a lot about appraisal quality. Also, I didn't make this up, and you can click the link to verify that:

"Not a golf or tennis player? Then go on a date!" said the ABS East brochure at its asset-backed securities conference in Orlando, Florida, which runs Sunday through Wednesday.

While not your traditional singles speed-dating event, the conference sponsor hoped to create some key matchups between issuers and investors seeking to form some true, long-lasting business partnerships.

"It just takes some of the guesswork out of trying to connect and makes a very large event more intimate for those people who may be new to the market or don't already have established connections," said Jade Friedensohn, IMN senior vice president and event producer.

Investors were offered the chance to meet one-on-one with issuers of mortgage asset-backed securities, collateralized debt obligations and non-mortgage ABS on Tuesday. Six investors and issuers spent 10 minutes in pairs of two hoping to make a connection before moving on to their next potential match.

"Ten minutes should be enough to determine if one investor's risk profile is in line with that issuer's platform. When you're first meeting, the goal is to even understand if there's compatibility there," said Friedensohn. "If there is, at that point, you've had face time, you've exchanged business cards and the follow-up can be done on-site or down the line."

(Thanks, scav (I think))

by Tanta on 10/30/2007 11:00:00 AM

Now and in the close of our escrow, amen.

How desperate are home sellers getting?

Item 1: Jewish Buddhist seller buries St. Joseph in the backyard. (Money quote: "I wasn't sure if it would be disrespectful for me, a Jewish Buddhist, to co-opt this saint for my real-estate purposes," says Ms. Luna, a writer. She figured, "Well, could it hurt?")

Item 2: Mortgage broker offers a deal to die for. (Money quote: "'Holy mackerel! This is unbelievable,'" Mr. Cook said.")

by Tanta on 10/26/2007 11:47:00 AM

This is killing me:

PHILADELPHIA (Dow Jones/AP) - Bankrupt lender American Home Mortgage Investment Corp. has sued Lehman Bros., accusing the investment bank of essentially stealing from the company as it struggled to stay on its feet.

The lawsuit, filed Wednesday in the U.S. Bankruptcy Court in Wilmington, Del., accuses Lehman Bros. of hitting American Home with improper margin calls in July and demanding money the company says it did not owe.

When the Melville, N.Y.-based lender couldn't meet Lehman's second margin call, for $7 million, Lehman foreclosed on $84 million worth of subordinated notes issued in American Home's structured-finance operation. . . .

American Home is relying in part on the frozen market for mortgage-industry paper to make its case against Lehman Bros. Without actual trades to show the value of the notes had declined, American Home argues that Lehman Bros. should have obtained an independent valuation before issuing the margin call.

That's an interesting theory of levering up your "assets": if the market says "no bid," you apparently get "no mark" and therefore "no call" and hence "no bankruptcy."

The thing is, in a nutshell, that AHM was using these borrowings to fund new mortgage origination operations. A "frozen market for mortgage-industry paper" means no money to make new loans with (proceeds from sales of commercial paper backed by the warehouse of held-for-sale loans) until you can sell the loans you've already made. But you can't sell the loans you've already made, unless you want to take a nasty hit on them, because nobody's buying decent whole loans in a "frozen market," and there is excellent reason to think AHM's warehouse held a boatload of not exactly decent loans. We know this because AHM was forced to visit the confessional about its massive number of buybacks of loans that didn't make the first three payments sucessfully.

So Lehman wanted out of its exposure to AHM's held for sale pipeline, as far as I can tell, because unlike your usual "pipeline," this one was a pipe to nowhere (kind of like the bridge to nowhere). It sounds like AHM is now saying that Lehman made up some ugly mark to model valuation instead of getting "independent" verification of the fact that there were no bids--or horrible ones--for the AHM loans. I guess the fact that AHM couldn't get 'em sold in the first place, which is the whole point of having a "held for sale pipeline," is insufficient evidence that the stuff was worthless.

I look forward to hearing about Lehman's response to this.

(Many thanks to the indefatiguable Clyde)

by Tanta on 10/15/2007 08:44:00 AM

Yves at naked capitalism has a post up this morning on the Citicorp-Related Asset Conduit Kerfuffle (MLEC), which I recommend.

There's also this charming bit from this morning's New York Times:

The problems raised alarms immediately in Washington, because commercial paper is a critical financial pillar for the economy, helping to provide money for home loans, credit cards and airplane leases. At the Treasury, Robert Steel, deputy under secretary for domestic finance, and Anthony Ryan, assistant secretary for financial markets, called top executives from about 30 banks to a meeting in Washington after realizing that the banks were not talking to one another about the crisis, people familiar with the talks said.

As a long-time observer of the banking industry, allow me to observe that one of our major problems has always been that we don't talk to anybody except each other. Trust a reporter to publish talking points about "pillars of the economy" and the Treasury just doin' a little healthy fostering of interbank communication skills.

From where I sit, it seems like a lot of investors no longer want to be the bagholder of the "pillars" of this economy, thanks. And Citicorp doesn't want to honor the guarantees it made to those SIVs in the first place, either. So instead of letting Citi take the consequences of having provided financial backstops to these things, the Treasury department thinks its a good idea to just "square" them (hey! it worked so well with CDOs!).

by Tanta on 10/13/2007 12:51:00 PM

In an attempt to keep my mind off of M-LEC, I decided to don a Hazmat suit and go see what those mortgage professionals over at Broker Universe are up to these days. I feel obligated to share this with you.

This is just a beaut:

Who can do Seller Carry Back Loans ?

In August 2005, husband and wife purchase a condo in San Mateo County, CA. for $400,000., and got 100% financing.

They did not occupy the condo, the wife’s brother moved in and he has been paying the mortgage, taxes, and HOA fees from the beginning.

The condo now has an appraised value of $460,000.

The total mortgage balance owed on the condo is $399,000.

The husband and wife would like to sell condo to the wife’s brother.

Can sellers do a 10% carry back, and let the buyer get a 90% purchase loan ?

Loan amount would be $414,000.

Who will do the 90% purchase loan ?

The good news is that, so far, no lender representative has responded to this offering to get screwed. The bad news is that, so far, no lender representative has asked for the broker's real name and state so that the lender can make sure this character is on all "debarred" lists.

The thing I really like about this scenario is that, while the odds are very good that parts of it are untrue, it's even worse if you assume it's all true. I mean, it's probably just some run-of-the-mill liar with a fake appraisal wanting to get out of a bad "investment." But imagine if it were true: there's a couple out there who "bought" a condo without risking any of their own money in down payment. They managed to sucker the brother into carrying the mortgage and all other ownership expenses. Now that they at least believe that the unit has appreciated by 15% in two years or so, they would like to extract that appreciation from their own relative by having him in essence assume their mortgage to get them out of any liability, plus pay them $15,000 out of loan proceeds, plus sign a note requiring him to pay them the balance of the "appreciation" over some period of years, with interest.

In Broker America, this is apparently considered a perfectly legitimate transaction.

by Tanta on 10/04/2007 08:49:00 AM

Reader Avinash sends us the following from "Creditflux," which is not something I made up either:

In a new research report entitled "Leveraging CLO illiquidity premia", JP Morgan says that the combination of historically wide CLO liability spreads and near-zero default rates makes this an optimal time for buy-and-hold investors to consider investing in CLOs-squared. It says this is a way to efficiently monetise the current illiquidity created in the "spread rout of 2007".

The report concludes that CLOs-squared offer reasonably low risk relative to the underlying CLOs. Junior tranches in particular offer higher spreads than triple B and double B tranches of regular CLOs with similar or lower risk.

The researchers point out that CLOs-squared are conceptually similar to ABS CDOs, but that they are better suited for leverage. Corporate loans are simpler than subprime mortgages and hence more predictable, argues the report.

Yes, that makes a great deal of sense. These stupid subprime borrowers have been taking mortgage loans that are more complex than corporate loans, but we have no idea why nobody seems to understand what got signed at the closing table. Also, it's an excellent time for investors to look for more leverage opportunities, because this whole problem, you see, was just a matter of the underlying collateral and had nothing whatsoever to do with levering up complex derivatives or having to unwind some goofy structured deal.

Just shoot me . . .