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QM Survey Report 2014

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This survey highlights change in Q2 2014 related to the QM rule, originators’ impressions of market dynamics, FHA, FHFA, and new credit scoring models.

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Executive Summary

Six months after the implementation of the QM/ATR rule, the market appears to be shifting modestly. This survey serves as both a measure of change in the 2nd quarter and a bellwether for originators’ impressions of market dynamics in light of regulatory changes under the QM/ATR rule as well as changes at the FHA, FHFA, and new credit scoring models. The panel was expanded in the 2nd quarter to include members of Community Mortgage Lenders of America.

Highlights of the Survey

• The non-QM share of originations more than tripled in the 2nd quarter to an originations-weighted 2.6% from 0.8% in the 1st quarter. Rebuttable presumption expanded as well to 12.8% from 9.8% over this same time frame.

• Respondents were less sanguine about their comfort with the QM/ATR rules in the 2nd quarter, with just 61.9% indicating that they had fully adapted compared to 73.7% in the 1st quarter.

• The share of lenders offering rebuttable presumption and non-QM products in the 2nd quarter improved, but willingness to originate non-QM and rebuttable presumption mortgages fell from the 1st quarter to the 2nd quarter. Lenders were more willing to originate prime mortgages, though.

• Over the next 6 months, nearly half of respondents expected improved access to credit for prime borrowers with FICO scores between 620 and 720. However, the vast majority expected no change for rebuttable presumption and non-QM borrowers. Respondents expect improved investor demand for all mortgage types

• Half of respondents indicated that the premium reductions under the FHA’s HAWK program were insufficient or the education fees were too high, while 55% indicated that the program would not expand credit.

• Only 15% of respondents felt that FHA’s program of early reviews would help to alleviate overlays.

• However, 85% of respondents indicated that a reduction of LLPAs directed at high LTV and low FICO borrowers would stimulate access to credit.

• Finally, 60% of respondents indicated that the Fair Isaac Company’s new FICO 9 scoring model would help to stimulate access to credit. Only 35% expected no change as they either defer to their investors’ or the GSEs’ scoring models.

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d. Relative toe most while

dents offered inate rebuttanon-FHA reb

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e presumption% expected it

ted for bufferQM mortgage.

f respondentelineation betndents indicaes, a decline

ot 2014, neacores between loans and 3t to weaken.

rs ahead of th. The use of bs employing otween rebuttated that theyfrom 22.2% l

rly half of resen 620 and 723.4% expecte

he QM parambuffers was mone. Only 9.1table presumy would not rast quarter.

spondents ex20. However,ed improvem

meters to prevmost common1% and 4.5% ption and safremove buffe

pected impro, the vast majent in the acc

vent producinn on the 3% cof responden

fe harbor staners even once

oved access tojority expecteces for non-Q

ng a rebuttabap and 43% b

nts used buffendard definiti they were

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QM borrowers

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rime e for s,

More than 40% of respondents expected investor demand for both rebuttable presumption QM and prime borrowers with credit scores between 620 and 720. Interest in non-QM lending was also expected to improve, roughly in line with that of high FICO, prime lending.

Other In

Under therepay a loasked whwillingnesthe produspace, witdefinitive reluctance

In the sumannual Mannual MThe educawhether tresponde20% felt tindicated

ndustry an

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e to originate

mmer of 2014IP and 50 bpsIP would fall ation programthe incentivesnts indicatedhat it would that the upfr

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me test can bve “bright lineright line” resttable presumual income tehey would be ld also help inower quality.

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be used as supe” proof of cosidual income

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either more n the non-QM

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pporting evidompliance wite test to the Qr non-QM spamost helpful likely or muc

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m that will ofplete a buyerborrower is n00 upfront. R

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elt that they were too high f

dence of a borth the rule. PQM/ATR wouace. Respondin the rebutta

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ogram. Only 1nd for FHA in

were not. 10%for consumer

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15% of nsurance, whi% of respondrs.

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n

onths.

ile ents

In its presdelinquencounselinprogram wthat theresomewha

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ss release for ncy rates of ug. Survey pawould affect e would be noat.

s also rolling e risk to lendo ameliorate

ed whether th

the HAWK prp to 30% for rticipants welenders’ credo change in ac

out a programders of proble

concerns abohe early revie

rogram, the Fcounseled bore asked wheit overlays onccess, while 2

m for earlier ems in loan filout buy-back

ews would im

FHA cited reseorrowers comether, given thn loans origin20% indicated

reviews of mes that couldrisk and to repact credit ov

earch that shmpared to sim

he evidence oated for the

d that it woul

ortgage files. lead to subseduce lenderverlays on loa

ows a reductmilar borrower

of reduced risFHA. A 55% md ease credit

. The programequent costly

r overlays in tans originated

ion in seriousrs without sk, the HAWKmajority indict tightness

m is intendedy put-backs. urn. Participd for the FHA

s

K cated

d to FHA’s ants

A.

60% indicsomewha

The FHFAwas approdemand iwhether athe creditbox, while

Finally, thgiven to t

cated that theat and signific

took commeopriate. Seven general anda reduction int box. A robue 20% felt tha

he Fair Isaac Che impact of

ere would be antly reduce

ents from the eral of the qued from high LTn LLPAs targetst majority of

at there woul

Corporation reunpaid medi

no change, woverlays. 10

public in earestions posedTV and low crted at lower Ff 80% felt thad be no chan

ecently introdcal bills and t

while 15% ind% defer to th

ly Septemberd by the FHFAredit borroweFICO and/or hat a reductionge.

duced a new the effect of m

icated that thheir investors’

r as to whethA dealt with ters. Survey phigher LTV bon in rates wou

scoring modemissed payme

he reviews wo’ rules.

er the currenhe impact of

participants worrowers wouuld help to ex

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ould both

nt g-fee structthe g-fees on

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A 60% maindicated while 35%GSE’s mar

ntly been paipoints for the nts were aske

ajority indicatthat it would

% deferred to rket share an

id off are elimformer group

ed if this new

ted that the nd not impact t

their investod their relian

minated. FICOp and by as mscoring mode

new scoring mtheir decision

or’s model or ce on an earl

O estimates thmuch as 100 pel would incre

model would in to accept asthat of the Gier FICO mod

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del.

model could i latter group.d application

epted applicatearlier versioult was a surp

improve scor. Survey

ns at their firm

tions. 5% on of the modprise given th

es by

m.

del, he

Appendix A: About the Survey

In August of 2014, NAR Research sent out a survey to a panel of 135 different mortgage originating entities. The panel was expanded in the second quarter from 65 to include members of Community Mortgage Lenders of America. The survey instrument was sent by email on Tuesday the 19th of August and closed on Tuesday, September 2nd. Questions in the survey instrument covered the characteristics of the originators, a subset of questions focused on the qualified mortgage rule, and a set of questions focused on the FHA, FHFA, and the new FICO 9 score. There were 24 unique responses to the survey for a response rate of 17.8% and a margin of error of 6.4% at a 95% level of confidence.

Mortgage bankers dominated this sample, but this sample had more diversity in terms of size of annual originations, a proxy for bank size. Originator profiles were also consistent with prior surveys in terms of geographic distribution, purchase share, average annual production volume, and the distribution of destinations/purchasers of the originator’s production.

Questions can be directed to:

Ken Fears Senior Economist, Director, Housing Finance and Regional Economics The National Association of REALTORS® [email protected] (202)383-1066

Kenneth R. Trepeta Esq. Director – Real Estate Services National Association of REALTORS® 500 New Jersey Ave, NW Washington, DC 20001 (202) 383-1294