The government-sponsored enterprises often require private mortgage insurance on mortgages with loan-to-value ratios above 80%. The coverage is often deeper than is even required by law and there are hints it could go to a lower LTV.
His first example was requiring private mortgage insurance on more loans guaranteed by the GSEs.
"A traditional way that the Enterprises shared risk with the private sector was through the use of private mortgage insurance," DeMarco said. "Consideration could be given to requiring greater mortgage insurance coverage, but doing so would need to be weighed against the financial condition of individual mortgage insurers."Where the PMI then goes against the Frank-Dodd rule.
If the FHFA adopted such a policy, it would clash against the current risk-retention proposal. According to a still pending rule proposed by federal regulators, lenders would not have to maintain the credit risk on a mortgage after securitization if the borrower puts 20% down and if other requirements are met as part of the qualified residential mortgage exemption. But no room was made for mortgage insurance under the QRM.Finally, fees are going up too.
He said the past degree of cross subsidization of certain product types will not be present in a private-dominant model. The FHFA will also take into account local economic conditions and state laws, specifically foreclosure timelines, when pricing the g-fees. Meaning, in places where it is more expensive and longer to foreclose, lenders could see g-fees go up. DeMarco also added that the fee competition between the GSEs would not be appropriate in the future, signaling an alignment of the fees between the two giants.Read it all