by Calculated Risk on 3/29/2007 03:01:00 PM

From Indymac: Additional Credit Loss Analysis on Alt-A and Subprime Lending

“Based on an objective analysis of the facts, talk of the ‘subprime contagion’ spreading to the Alt-A sector of the mortgage market is, in our view, overblown. Cumulative mortgage industry Alt-A loan losses over the last five years are 1/17th the loan losses for subprime loans based on the FALP data. In addition, as of Dec. 31, 2006, the 30+day delinquency percentage for Alt-A loans in the mortgage industry was 5.0 percent as compared to 21.7 percent for subprime loans, suggesting that the differential in loan loss performance for Alt-A versus subprime will continue into the future.”
Michael W. Perry, Indymac’s Chairman and CEO, March 29, 2007

I don't think anyone was suggesting that Alt-A delinquency rates would be as high as subprime. So Mr. Perry is creating a strawman here.

The suggestion is that Alt-A would see a substantial increase in delinquency rates, and, as a result, the sector specific credit crunch (with tighter lending standards) would also impact Alt-A. This is already happening. Yesterday I posted the analysis from ResCap of their new lending standards on 2006 originations. ResCap estimated that their new guidelines would have eliminated 20% of Alt-A loans in 2006.

The subprime contagion is already here.

by Anonymous on 3/29/2007 01:15:00 PM

The AP reports on delinquencies for consumer credit:

The American Bankers Association, in its quarterly survey of consumer loans, reported Thursday that late payments on home equity loans rose to 1.92 percent in the October-December period. That was up sharply from 1.79 percent in the prior quarter and the highest since the first quarter of 2006. . . .

A separate survey released earlier this month by the Mortgage Bankers Association showed a big jump in late mortgage payments in the final quarter of last year, news that caused stocks on Wall Street to swoon.

The American Bankers Association's survey, meanwhile, also showed that the delinquency rate on “indirect” auto loans, which are arranged through dealerships, shot up to 2.57 percent in the fourth quarter, the highest since the second quarter of 2001, when the economy was in a recession. Late payments on other auto loans, however, dipped slightly.

The survey also showed that the percentage of credit card payments past due was 4.56 percent in the fourth quarter, down slightly from 4.57 percent in the third quarter.

Late payments on boat loans rose, while delinquent payment on mobile homes went down.

by Calculated Risk on 3/29/2007 01:08:00 PM

From the San Diego Union: Home loan defaults skyrocket in county

Homeowners throughout San Diego County are defaulting on their loans and losing their properties to foreclosure at an increasingly rapid pace, a shattering event that nevertheless remains far less extensive here than the mortgage problems arising elsewhere in the nation.

In the first two months of the year, there were four times more default notices issued in the county than in the first two months of last year, while foreclosures tripled over the same period, according to an analysis of data provided by locally based DataQuick Information Systems.

by Anonymous on 3/29/2007 06:57:00 AM

My post yesterday on Sandra Braunstein's remarks on subprime lending brought up the issue of disclosures to consumers. As you may or may not know, there is an existing Regulation Z that requires lenders to provide ARM loan program disclosures to consumers no later than the time of application for an ARM loan. These disclosures are supposed to help the borrower understand the mechanics of the loan. Reg Z does not require specific text, although it does supply example text. It does spell out in some detail what issues must be addressed in the disclosures. Lenders usually choose to have different disclosure documents for different ARM types; a lender using a very long "multipurpose" disclosure risks having its good faith challenged.

Reg Z has been around forever; that's important to remember given the current situation we have of borrowers (not to mention brokers) who clearly don't understand the terms of these loans. The item on the agenda of someone like Braunstein is whether and how Reg Z may need to be supplemented or superceded with new disclosure requirements. Politically speaking, lenders generally lobby against any such changes to the regs, if for no other reason than that they don't want to go to the additional effort and expense of changing all the disclosures they currently use. You may conclude that at least some lenders have other reasons to object, namely that--theoretically, at least--a clearer disclosure of loan terms might lead some borrowers to refuse to accept some of these products.

I will be the first to admit that it's a struggle for someone like me to judge the adequacy of a Reg Z disclosure. Obviously, I can and do review them for accuracy. But there's a big difference between a statement being true and a statement being comprehensible or useful to a non-expert. And experts can quickly lose their ability to appreciate the difficulties of non-experts. In my view, that's one of the biggest problems with regulatory disclosure requirements: the "final sign off" is from some lawyer, not from the sort of non-lawyer non-expert for whom the document is designed.

Furthermore, these documents need to be viewed not just in terms of their intended readers' expertise, but also in the context in which they are provided. Over the years so many different disclosures and documents have accumulated in the "application package" that you cannot really judge the accessibility of a single document without bearing in mind all the other documents for the borrower to absorb.

And, of course, that borrower has only some period of time in which to absorb things. Those who are all in favor of the 12-second approval using high-speed technology are always those who counsel the borrower to take his time, take the docs home over the weekend, consult a friend about them, do some web-surfing, there's no hurry here, make sure you understand this before you cough up a nonrefundable application fee . . . right? I'm not anti-technology or anti-AUS, but I continue to have huge problems with using it at point of application, and selling the speed as an advantage. The assumption that any borrower should be in that much of a hurry to borrow that much money at that complicated a set of loan terms makes my skin crawl.

But perhaps I underestimate the borrower? Well, you tell me. Here's Thornburg Mortgage's 1-Month LIBOR Option ARM disclosure, and here's the corresponding Note. I chose these not just because they're freely available on the web, but also because in my opinion Thornburg's disclosure is as well and clearly written as they tend to come. So this is not a test of the worst disclosures out there.

I would be truly interested in what you all make of these documents. If you read my UberNerd post on neg am, or you've had one of these before, or you're in some part of the mortgage business, please bear in mind that you have more background information than the intended reader of the disclosure. If it only makes sense to an expert, or even just to a more than usually informed non-expert, then it isn't doing what Reg Z intended it to do.

by Calculated Risk on 3/28/2007 05:30:00 PM

Here is the presentation from the ResCap / GMAC Financial Services 2007 Investor Forum.

ResCap evaulated the impact of the their new underwriting guidelines on their 2006 vintage portfolio (hat tip Brian). The new guidelines would have eliminated 58% of subprime loans, 20% of Alt-A loans and 35% of all 2nds. Wow!