Mortgage originators, servicers, and secondary market participants should take note that the October 1 implementation date for the Interagency AVM Quality Control Rule (the “Rule”) is fast approaching....more
I am joining the hordes occupying the chatter-sphere to opine about what the GSEs should look like, post conservatorship. Having reviewed loads of opinions about the future of the Twins, I’m pretty sure the bar on looking...more
Trusts are being used more often for financing mortgage loans, which can be an effective way to optimize asset management and minimize lender risk. Key Benefits of Using Trusts in Mortgage Loan Financing...more
We have seen a marked increase in the volume of structured finance transactions involving lifetime mortgage products in recent years (both funding transactions and the sale and purchase of lifetime mortgage books through...more
The FCA issued a consultation paper on 7 May 2025 seeking feedback on regulatory proposals to simplify advice rules and affordability assessments for mortgages, making it easier, faster and cheaper for consumers to make...more
On April 2, the U.S. District Court for the Northern District of Texas granted defendant Ginnie Mae’s motion for summary judgment in a dispute concerning Ginnie Mae’s Home Equity Conversion Mortgage (HECM) mortgage-backed...more
Welcome to the latest edition of the Spectrum, covering hot-topic issues in the structured finance markets in the U.S. and UK. This edition features a close look at business development companies, an introduction to project...more
A bank sought payment under “deeds of indemnity” related to swap agreements which were part of a number of Dutch mortgage-backed securitisations. The mortgage provider refused to pay, a key argument being that the “deeds...more
As regular readers of CrunchedCredit will know, I recently pitched the idea of amending our hoary old REMIC statute to allow additions of collateral after the startup date window to allow modification to performing loans (and...more
This title may be a bit ambitious, a triumphalist embrace of hope over experience? But it’s time for the effort to be made....more
What Happened? A development with far-reaching consequences for the secondary market, on January 10, 2025, the Maryland Office of Financial Regulation (“OFR”) issued guidance that requires mortgage trusts and their assignees...more
Welcome to the latest edition of the Spectrum, covering hot-topic issues in the structured finance markets in the U.S. and UK. This edition features the new UK securitization regime, eHELOCs, and climate risk disclosures....more
On June 6, 2024 federal regulators published a final rule addressing Quality Control Standards for Automated Valuation Models. This was a collaborative rulemaking effort that included regulators from the Office of the...more
On 5 March 2024, the European Commission adopted a delegated regulation that will supplement the EU Securitisation Regulation with regulatory technical standards ("RTS") in relation to simple, transparent and standardised...more
As we begin to reflate the CRE CLO business this year with shrinking spreads and hopefully shrinking SOFR, we need to think of this as CRE CLO 3.0. This business, this technology, which is truly a brilliant way to deliver...more
Welcome to the latest edition of the Spectrum, covering hot-topic issues in the structured finance markets in the U.S. and UK. This edition features the shifting single-family rental landscape, what’s next for EDGAR, and...more
On June 21, 2023, the Office of the Comptroller of the Currency (OCC), Treasury, Board of Governors of the Federal Reserve System (Board), Federal Deposit Insurance Corporation (FDIC), National Credit Union Administration...more
Banking organizations looking to reduce the amount of risk-based regulatory capital required to support residential mortgage loan portfolios can use synthetic securitization to convert the capital treatment of their exposures...more
Under the REMIC rules, a mortgage loan ceases to be a good REMIC asset if the borrower replaces the real property collateral with government securities (known as defeasance) less than two years after the REMIC’s startup date....more
On March 17, 2022, the New York State Court of Appeals issued a significant decision affecting RMBS putback litigation governed by New York law. The decision, U.S. Bank National Association v. DLJ Mortgage Capital, 2022 WL...more
Ginnie Mae clarifies its MBS Guide with respect to seasoning of VA IRRRLs that are a “Refinance of a Modified Loan.” Issuers had challenged Ginnie Mae’s buy out demands that claimed insufficient seasoning when measured from...more
Issuers should be aware that Ginnie Mae interpreting its MBS guide in a manner that departs from VA circular 26-19-22, and the plain reading of statutory language with respect to the beginning and ending dates used to...more
The Internal Revenue Service (IRS) issued Revenue Procedure 2021-12 on January 14, extending the safe harbors in Revenue Procedures 2020-26 and 2020-34 to September 30, 2021. This LawFlash discusses the portion of Revenue...more
The Internal Revenue Service (IRS) issued Revenue Procedure 2020-26 on April 13, 2020, providing relief to certain securitization vehicles, including investment trusts and real estate mortgage investment conduits (REMICs),...more
The Internal Revenue Service on Monday, April 13 issued welcome relief to the securitization industry, providing that certain forbearances and related modifications to mortgages will generally not cause real estate mortgage...more