by Anonymous on 8/18/2007 01:00:00 PM

This is basically just the result of a "random play" move I made the other day. For some reason the tune's been sticking with me. Apologies for the video, but maybe it'll calm everyone's nerves.

Enjoy.

by Anonymous on 8/18/2007 12:56:00 PM

I got my hands on another investment bank analysis of loan modifications—this one is Lehman’s (thanks, Clyde!). Like every other analysis from the IBs and the rating agencies that I have seen in the last two or three months, it concludes that modifications are usually allowable by the securitization trusts, and done correctly they are either loss-neutral (to the top tranches) or actual loss-mitigation (to the bottom tranches), and therefore advisable under careful terms and practices of the servicer.

What was interesting about the Lehman analysis is that it looked quite squarely at the possibility of what it calls the “moral hazard borrower,” or some set of borrowers ending up getting a mod when they wouldn’t have defaulted (or could have gotten a market-rate refi) because the servicer’s “targeting” was too wide. They conclude, actually, that with careful enough cost-to-trust analysis of the terms offered on all mods, and limiting mods to borrowers who have already become delinquent, the “moral hazard borrower” problem isn’t likely to cause noticeable losses.

If I get permission from Lehman I’ll post some more of the analysis. Until then I think I can get away with this snippet regarding the methodology of their analysis, which I bring up for discussion purposes:

In our scenario, we assumed that the proportion of the borrower pool in each of these groups [current borrowers, those who can be cured with a mod, those who cannot be cured, the “moral hazard borrower”] depends on the amount of rate or payment reduction. Because we did not have data on borrower responsiveness to loan modifications, we extrapolated the sensitivity of defaults from observed response of subprime ARMs to payment shocks. A 9% payment shock on subprime ARMs has historically caused about a 20% increase in the credit default rate (CDR). The experience from payment shocks is not entirely applicable to the loan modification scenario as subprime ARM borrowers who choose to stay on with their mortgage post-reset are adversely self-selected. The higher default rates from this self-selection cannot be directly distinguished from the economic impact of the payment shock. However, given the lack of data on the likely impact of loan modification, we are using the response to payment shocks as a proxy for the impact of loan modifications.

What might it mean to say that “borrowers who choose to stay on with their mortgage post-reset are adversely self-selected”?

First, we must assume that a choice is a choice. We therefore assume that there are alternatives, such as a refinance at a rate/payment lower than the reset rate/payment that these borrowers could qualify for but choose not to, or that the property could be sold without financial hardship to the borrower, or the borrower could simply mail in the keys.

Any borrower who “chooses” to keep a loan with a 6.50% margin that resets every six months instead of refinancing or selling at break-even or walking away is, therefore, presumed to be:

1. Uninformed
2. Irrational
3. Masochistic
4. Making plans to scarper
5. Running a tax dodge
6. So traumatized by the original experience with a loan broker that he or she is unable to contemplate going through that again even if it means starving
7. A couple of tranches short of a full six-pack, if you know what we mean.

The inescapable conclusion (you might want to sit down for this, it’s stunning) is that it is very difficult to model the behavior of this group with the usual variables like “in the money rate incentives” or “moral hazard” or “damage to credit rating” or “pupil dilation in presence of bright lights.”

At this point, we merely pause to recognize the nature of what this is saying about the subprime 2/28 and 3/27 ARM: it was never intended to be a 30-year loan. It was always a bridge loan pretending to be a 30-year loan. It cannot be modeled as a 30-year loan. But hey! It’s a great product for achieving stable homeownership goals!

In any event, as of today we’re well past that point where “choice” and “self-selection” are the operative mechanisms. In the current environment, we have:

1. Little available refinance money (lenders are not lending)
2. Little available refinance incentive (refi rates are high when they are available)
3. Little available refinance flexibility on high LTVs (the “add-on” cost for a high-LTV loan is no longer artificially lowered by “nontraditional loan products” manipulating the payment)
4. Little opportunity to sell for at least the loan amount plus transaction costs

This means, as far as I’m concerned, that it is quite likely that the universe of “post-reset borrowers” is no longer adversely self-selected. It may well be adversely selected: “little opportunity” to sell or refi does not mean “no opportunity,” and so the very highest-quality borrowers and the properties in the healthiest RE markets will opt out of the pool. But your remaining pool is not the “classic” self-selected group any longer.

This is why workout options like mods start to make sense: the pool of defaulting borrowers is no longer exclusively the group of people for whom little can be done; the pool includes people for whom the credit crunch removed what could have been a viable option. In a credit crunch, the model that assumed “adverse self-selection” no longer works reliably.

Beyond The Great Modification Controversy, I think it’s worthwhile to return to this question of how much “historical” data we ever had to justify all the risk we put into the system during the great lending bubble. A lot of people cheerfully made these 2/28s because they based their “stress test scenarios” on past episodes of economic or housing market distress in which different products were offered to borrowers (either fixed rate loans or straight “bullet” ARMs that don’t have this initial teaser/IO fixed period/prepayment penalty combo). The only excuse for this, which is now becoming explicit, is that we just counted on easy refi money and endless HPA to take care of the problem. I know that’s not news to the Calculated Risk crowd, but it still seems to be news to these CEOs (ahem) who stand up and say “no one saw this coming” and “we didn’t lend on appraised values.”

by Calculated Risk on 8/18/2007 01:15:00 AM

From Reuters: Sentinel files for Chapter 11 bankruptcy

Sentinel Management Group Inc., a U.S. futures commission merchant whose decision to freeze client accounts on Tuesday helped roil global financial markets, filed for Chapter 11 bankruptcy protection late on Friday.

The cash management company, which managed about $1.6 billion of assets, said its board decided it was in "the best interests of the corporation, its creditors and other interested parties that a voluntary petition be filed ... in an effort to restructure the indebtedness of the corporation," according to a filing in the bankruptcy court for the Northern District of Illinois.

Here is the Bloomberg article with more details.

by Calculated Risk on 8/18/2007 12:50:00 AM

WaPo: Fannie Mae Predicts Price Decline Will Accelerate in '08

Fannie Mae, the mortgage finance giant, yesterday predicted that housing prices will decline by 2 percent on average this year and by 4 percent next year as mortgage delinquencies rise, lenders tighten borrowing standards and the volume of unsold homes approaches record levels.

"This is clearly a market poised for more severe overall credit losses," Enrico Dallavecchia, Fannie Mae's chief risk officer, said in a conference call with investment analysts.

Adding to the trouble, Dallavecchia said, is that many borrowers with adjustable-rate mortgages are facing rising monthly payments, which could drive them into foreclosure. "This could have a cascading effect in the market," he said.

A 2% price decline nationwide - as measured by OFHEO - sounds about right for 2007. I also expect the pace of price declines to increase next year.

by Calculated Risk on 8/17/2007 08:09:00 PM

From the WSJ: Using Discount Window Is Sign of Strength, Fed Says

... the Federal Reserve held a conference call with major banks to encourage them to consider borrowing from the central bank’s discount window.

... Fed officials know the discount window action will only be effective if banks either use it, or the knowledge of its availability, to expand their own lending to high-quality counterparties such as high quality mortgage borrowers.

The participants from the banking world included ABN AMRO; Bank of America; The Bank of New York Mellon; The Bank of Tokyo-Mitsubishi UFJ, Ltd.; The Bear Stearns Companies Inc.; Citigroup; Deutsche Bank Group; Goldman Sachs; JPMorgan Chase & Co.; Lehman Brothers; Merrill Lynch; Morgan Stanley; UBS; U.S. Bank; Wachovia; and Wells Fargo.

by Calculated Risk on 8/17/2007 04:08:00 PM

From Paul Krugman: Workouts, Not Bailouts. Excerpts are from Economist's View.

... if historical relationships are any guide, home prices are still way too high. The housing slump will probably be with us for years, not months.

Meanwhile, it’s becoming clear that the mortgage problem is anything but contained. ... Many on Wall Street are clamoring for a bailout — for Fannie Mae or the Federal Reserve or someone to step in and buy mortgage-backed securities from troubled hedge funds. But that would be like having the taxpayers bail out Enron or WorldCom when they went bust — it would be saving bad actors from the consequences of their misdeeds.

And Krugman argues for workouts, not bailouts:

Consider a borrower who can’t meet his or her mortgage payments and is facing foreclosure. In the past, ... the bank that made the loan would often have been willing to offer a workout, modifying the loan’s terms to make it affordable, because what the borrower was able to pay would be worth more to the bank than its incurring the costs of foreclosure and trying to resell the home. That would have been especially likely in the face of a depressed housing market.

Today, however, the ... mortgage was bundled with others and sold to investment banks, who in turn sliced and diced the claims to produce artificial assets ... And the result is that there’s nobody to deal with.
...
The federal government shouldn’t be providing bailouts, but it should be helping to arrange workouts. ... Say no to bailouts — but let’s help borrowers work things out.

Tanta has written about the servicer issues. For an overview of how servicing works, see: Mortgage Servicing.

Tanta also wrote about some of the servicer vs. investor conflicts in SFAS 140: Like A Bridge Over Troubled Bong Water. Tanta concluded:

The time to have gotten fired up about the real issues around off balance sheet securitization--the great "de-linking" of risk that was openly advertised as the benefit to the investor of all of this--was back when those 2/28s were being originated. We here at Calculated Risk were on it back then, and being dismissed as "bubbleheads." Absolutely nobody, as far as I know, is happy with any of the bad choices we now have since we've gone into cleanup mode. But this desperate attempt to keep the moral hazard in place, whether it's Cramer begging for a rate cut or bond investors demanding that FASB shoot the wounded, sink the lifeboats, and close the gates of mercy to protect the interests of the AAA crowd, is a little hard to take.

Sit down, boys and girls. There has always been an "information asymmetry" issue with mortgage-backeds. The originator has always known more than you know. The servicer has always known more than you know. The auditors have always known more about the balance sheet ingredients than you have. This problem did not arise a couple of months ago when the ABX tanked.

It has also always been the case that the party on the other side of that cash-flow is Joe and Jane Homeowner. Taxpayer, voter, citizen, parent, child, grannie and gramps, your neighbor. This is a group of folks it's a bit hard to demonize. We've been trying, with this "it's all subprime and all subprime borrowers are deadbeats" meme, but except for a few dead-ender holdouts, that dog is no longer barking. No one will be less surprised than I to find many politicians doing the wrong thing here, out of a misguided sense that something must be done, and seen to be done. Possibly someone will do something sane and useful.

Perhaps Krugman is proposing something 'sane and useful'.

UPDATE: Here is an example of bad ideas from Senator Schumer yesterday.

Senator Charles E. Schumer today renewed his call on the Bush administration to immediately lift the portfolio cap on Fannie Mae and Freddie Mac to help ease the liquidity concerns in the mortgage markets. Schumer added that if Fannie and Freddie’s regulator doesn’t act soon to temporarily allow the companies to provide more liquidity, he will introduce legislation to do so as soon as Congress reconvenes in early September.

by Anonymous on 8/17/2007 01:23:00 PM

Or mortgage brokers will get like totally bummed out.

CHICAGO (MarketWatch) -- There's more at stake in Countrywide's health than the future of the company -- if it isn't able to keep making loans, the psychological impact of the loss would be felt directly by consumers, participants in a California Association of Mortgage Brokers news conference said on Thursday.

"The consumer will feel that there is no loan availability if companies like Countrywide can't keep their doors open. This isn't some small company that decided to start up yesterday that had a risky business plan. This is America's leading lender," said Ed Craine, the public relations chairman of the group.

"The credit crunch is working its way through the whole market, taking companies we've seen as solid companies that nobody would ever expect to have problems and putting them on the brink of disaster."

As it is, certain mortgage products have been drying up and lending guidelines have been tightened -- "changing almost hourly," as the California group said in a news release. Lenders who have shut their doors this year have also reduced consumer options.

The problems Countrywide is having are proof of the depth of the market's current troubles, said John Marcell, who served as the group's president from 2005 to 2006.

"It just goes to show you the state that the market is in right now when you have the largest mortgage lender in the United States having these kind of difficulties," Marcell said. "We're going to have to get some relief some place to keep companies like this still in business."

by Calculated Risk on 8/17/2007 11:07:00 AM

Perhaps the Fed was trying to provide liquidity to CFC.

From the LA Times: Worried about the stability of mortgage giant Countrywide Financial, depositors crowd branches.

Anxious customers jammed the phone lines and website of Countrywide Bank and crowded its branch offices to pull out their savings because of concerns about the financial problems of the mortgage lender that owns the bank.
...
At Countrywide Bank offices, in a scene rare since the U.S. savings-and-loan crisis ended in the early '90s, so many people showed up to take out some or all of their money that in some cases they had to leave their names.

by Calculated Risk on 8/17/2007 10:11:00 AM

From the Fed:

Financial market conditions have deteriorated, and tighter credit conditions and increased uncertainty have the potential to restrain economic growth going forward. In these circumstances, although recent data suggest that the economy has continued to expand at a moderate pace, the Federal Open Market Committee judges that the downside risks to growth have increased appreciably. The Committee is monitoring the situation and is prepared to act as needed to mitigate the adverse effects on the economy arising from the disruptions in financial markets.

And more:

To promote the restoration of orderly conditions in financial markets, the Federal Reserve Board approved temporary changes to its primary credit discount window facility. The Board approved a 50 basis point reduction in the primary credit rate to 5-3/4 percent, to narrow the spread between the primary credit rate and the Federal Open Market Committee's target federal funds rate to 50 basis points. The Board is also announcing a change to the Reserve Banks' usual practices to allow the provision of term financing for as long as 30 days, renewable by the borrower. These changes will remain in place until the Federal Reserve determines that market liquidity has improved materially. These changes are designed to provide depositories with greater assurance about the cost and availability of funding. The Federal Reserve will continue to accept a broad range of collateral for discount window loans, including home mortgages and related assets. Existing collateral margins will be maintained. In taking this action, the Board approved the requests submitted by the Boards of Directors of the Federal Reserve Banks of New York and San Francisco.

From the WSJ: Explaining the Discount Window

The discount window is a channel for banks and thrifts to borrow directly from the Fed rather than in the markets. ... A few years ago the Fed overhauled the discount window ... the rate was then set one percentage point above the funds rate and subject to far fewer conditions. ... discount window borrowing has remained paltry. Discount lending averaged just $11 million in the week ended Aug. 15. Although that was up from $1 million in the prior week it was puny compared to the billions of dollars the Fed has regularly injected into the financial system through open market operations.

Fed officials hope that reducing the penalty rate associated with the window and lengthening the term of loans to 30 days from one ... and gives it a tool to supplement open market operations for reliquefying markets. ... The discount window however is available to any bank or thrift, and the terms are easier than for fed funds loans. For example, banks may submit mortgage loans, including subprime loans that aren’t impaired, as collateral, and many probably will.

by Anonymous on 8/17/2007 07:45:00 AM

The question of falling yields on the low end of the curve and ARM resets comes up periodically in the comments. I offer a few UberNerdly tidbits of information about that.

First, review: an ARM adjusts to a rate equal to index plus margin. The index used and the margin, expressed as points, are spelled out in the note, as is the “reset” date. Your note will call this a “Change Date.” There are rate Change Dates and payment Change Dates. In an amortizing or interest-only loan, the payment changes on the first day of the month following the rate change. (Interest is paid in arrears on a mortgage loan.)

The index used will have a “maturity” equivalent to the frequency of the rate adjustments once the loan gets past its initial fixed period (if it has one). A true 3/1 ARM will adjust every year after the first three years, and so it will be indexed to some kind of 12-month money. The 2/28 and 3/27 are so-called to distinguish them from a 2/1 and 3/1; the 2/28s reset every six months after the first two years, not every year thereafter. (This convention is not consistent across the industry, I’m afraid. There are many, many Alt-As out there labeled as 5/1s that are really 5/25s.)

The “traditional” ARM was indexed to constant-maturity Treasuries (CMT). Almost all ARMs with a 6-month reset are indexed to LIBOR, but plenty of loans these days with a 1-year reset are indexed to LIBOR. LIBOR comes in 6-month and 12-month versions, just like Treasuries.

So the note for a 2/28 will say that the new interest rate will be equal to the 6-month LIBOR value plus the margin, usually rounded to the nearest eighth, subject to the adjustment caps, as of a certain date. Most 2/28s have caps you will see indicated as “2/1/6.” That means that the rate cannot go up or down more than 2.00 points at the first adjustment; it cannot go up or down more than 1.00 point at any adjustment after the first one; and it cannot go up more than 6.00 points over the life of the loan. (Unless you’re dealing with a real slimy lender who puts a “floor” on your ARM, so that it cannot go up or down more than 6.00 points over its lifetime. That’s all too common in subprime, but not in Alt-A or prime. The GSEs will not allow “floors” on an ARM: the rate can go down as far as the formula index plus margin can go down.)

The note will also indicate the time that the new index value is established. This is called a “lookback period,” although you will not see the term “lookback” in your note. All ARMs indexed to the one-year Treasury, and some other ARMs, will have a 45-day lookback period, which means that the new index value will be “the most recent index figure available as of the date 45 days before each Change Date.” This 45-day period was established as “standard” back in the old days, when lenders got information about indices from statistical releases published by the Fed on paper and sent out in snail mail; the servicer often didn’t have the “most recent” index value until some point in the month prior to that Change Date, which occurs on the first. But to keep things uniform and fair to the borrower, the value was the one in effect 45 days prior to the change, even if the lender didn’t get that info until two weeks before the change, when it could start updating its index tables on its servicing system (or having Marge in servicing get out the ledger book and a sharp pencil).

Almost all ARMs with a LIBOR index, on the other hand, have a “first business day” lookback. That means that the index value used is “the most recent value as of the first business day of the month immediately preceding the month in which the change occurs.” These notes specify that the source of the LIBOR index is the Wall Street Journal; there wasn’t much of a time delay in getting the WSJ for servicers even back before the internet.

So anybody with an annually-adjusting ARM with a reset date of October 1 will have gotten the August 15 index value. Anybody with a semi-annual ARM (like a 2/28) will get the index value in effect on September 3. In both of those cases the new payment at the adjusted rate will start on November 1.

Margins on prime ARMs are usually 2.75 for Treasury ARMs and 2.50-2.75 for LIBORs. Alt-A is generally 2.75-3.50 or thereabouts; the “risk-based pricing” adjustments will vary by the amount of risk-layering on the loan. Subprime can range from 3.50 to 6.50, again depending on loan quality and other terms.

A 2/28 with a start rate of 8.50% that has its first adjustment on September 1 and a margin of 6.50% will have a “fully-indexed” value of 11.82688 (6 Month WSJ LIBOR on 8/1/07 = 5.32688). Rounded to the nearest eighth that’s 11.875%. Since that is more than the maximum first adjustment cap of 2.00% allows, the rate adjusts to 10.50%. At the next 6-month adjustment, it can go up another 1.00 point. It does not stop going up unless and until it hits a fully-indexed rate of 14.50%, which is the lifetime cap (start rate plus 6.00%).

A lot of the modifications that are going on right now involve servicers taking a look at that 6.50% margin. If, in fact, the borrower did make the first 24 payments on time, there’s an argument to be made that that margin could come down to something closer to Alt-A or near-prime. If you modified the note to bring the margin on the example loan above down to 3.50%, you’d get the rate resetting to 8.875% instead of 10.50%. On a $100,000 loan, that would be a payment of $807.49 versus $924.50. If you made that modification subject to future modification back to 6.50% if the borrower doesn’t perform, you are, possibly, offering an incentive for continued performance. And if the borrower continues to perform, it’s hard to understand why you’d still call it “subprime.” Credit grades are snapshots in time, not prisoner tattoos.

“Normally,” of course, people who take subprime loans and manage to perform for at least 24 months are supposed to refi into a nice cheap prime loan. Now that LTVs are just too high for that, some people are going to have to stay in the loan they’re in. There may only be a few subprime borrowers who fit this case—who have made the first 24 payments on time, can handle an adjustment from 8.50% to 8.875%, and want to continue to own the home—but I’m damned if I can see why we shouldn’t do margin-mods for those few. 350 bps is a fair margin over credit risk-free money for someone who is making the payment every month. Sure, it might mess up your excess spread calculations on your ABS, but foreclosing will mess it up worse.

That said, please note that we’d have to have a miraculous LIBOR rally to help out anyone with a 6.50% margin and an 8.50% start rate: the 6-month LIBOR would have to hit 2.00% on the first business day of the month before the reset date to keep that loan flat. Those nasty neg am ARMs with rates that reset monthly, based on a monthly index, might get some short-term slowing in the rate of negative amortization, but it’ll take a long, long stretch of low short rates to bail those things out.