With all eyes on the turmoil in the banking sector, it’s good to see that policymakers continue to innovate to help borrowers. Earlier this month, HUD published Mortgagee Letter 2023-06 “Establishment of the 40-Year Loan Modification Loss Mitigation Option”, which establishes the 40-year standalone Loan Modification into FHA’s COVID-19 Loss Mitigation policies[1]. The standalone 40-yr mod is scheduled to be implemented by May 8. This follows the establishment of a 40-yr modification with a partial claim in April 2022[2]. The introduction of standalone 40-yr mods reminded us that we haven’t focused on the progress of the 40-year mod with a partial claim identified by pool prefix “ET”. Below find a chart of issuance by program:

As policy interest rates continue to rise and economic activity begins to slow, attention in the mortgage market shifts towards concerns about the potential for borrower distress. We are early in this process as the labor market continues to add jobs, and there continue to be more job openings than people looking for work. Nonetheless, signs of strain begin to be seen, and it's worthwhile to point out early trends and consider implications.
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Notably, the impact of Hurricane Ian could be seen in the short-term delinquency data:

In previous posts, we discussed the trends in Ginnie Mae MBS issuance by loan purpose.[1] Recall that the decision to buy a loan out of a Ginnie pool rests with the servicer. As such, this decision is dependent in part on environmental factors that impact the profitability of this action, notably the interest rate. As loans get bought out at par, there is a greater incentive to purchase loans out of pools and get them into reperforming status when rates are low than when they are high. This relationship can be clearly seen in the following graphs:

Analyzing trends in market performance requires two things, 1) a lot of data, and, 2) a deep understanding of the structure of markets. We recently came across a good example of this with relative delinquency rates between GNM and GSE pools[1]. In this post, we look at the dynamics of the two categories of reperforming mortgage loans.

Investors have spent many years building models of prepayment speeds for mortgage pools based on a variety of characteristics such as loan size and underwriting characteristics. However, institutional factors can come into play as well. One that comes to mind is the difference in program structure between conventional and government loans. For the conforming market, the issuer is a GSE, while for government programs, it is the servicer. In both categories, when a loan becomes seriously delinquent, it can be bought out of the pool at par, amounting to a prepayment. The difference is that for the case of conforming loans, it is the quasi-public GSEs that perform this function, while for government programs, the decision is up to private sector entities. In the first case, there are overarching policy goals that weigh on decisions about the disposition of loans in delinquency, while in the second case, these decisions are based on financial considerations.

One way to test this is to look at buyouts over the interest rate cycle. Below find a chart containing the shares of reperforming loans in new issuance for FHA, VA and the GSEs. These are loans that have been previously bought out of pools and then reissued into new pools. There can be a substantial lag between the buyout and re-issuance.

With the 30-year mortgage rate surging to a 13-year high near 5 ¼% and the FHFA purchase-only house price index at a record-high 19.42% in February (edging out the prior record of 19.39% in July 2021), we are in an unprecedented environment in the mortgage market. As such, it makes sense to update our analysis of the trend in issuance updated through April. Of particular interest in this regard are the FHA and VA programs.
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Let’s start by looking at FHA. By loan count, there were 107,500 FHA loans issued in GNM pools in April, with a decline of over 1/3 from the same month a year earlier. One special interest is the evolution of the share of issuance by loan purpose:

In a recent post[1], we discussed the disposition of loans that are exiting forbearance programs. In the Ginnie Mae programs, many loans bought out of pools have received modifications or other workouts, and then redelivered to Ginnie Mae pools. However, we have historically observed that there are more loans bought out than re-delivered, even considering the time needed for the workout.  As it turns out, there are other market-based outlets for these loans, which is more evident at the issuer level than in aggregate.

Below find a chart of buyout and securitization activities within Ginnie Mae program for Lakeview, the third-largest Ginnie Mae servicer as of April 2022.

With the expiration of forbearance programs underway, there is an interesting question about how loans exiting these programs will perform once they are resecuritized. For Ginnie Mae programs, these are either loans that exit forbearance with a partial claim or receive a permanent mod under the various waterfall options in the FHA or VA programs. In our previous blogs[1], we have noted MOD and RG loans are becoming a significant portion of loans delivered to newly issued Ginnie Mae pools.

In a recent post, we mentioned that the 24-month timeline for the purchase of delinquent loans out of pools implied that this activity would not pick up until April 2020[1]. However, some leading indicator of loan disposition was available through the release of trial modification data in the Borrower Assistance Plan (BAP) field released in the monthly Agency disclosures. Once loans have completed three months of successful payments in this plan, they are eligible to be purchased out for the commencement of a permanent modification, and eventual resecuritization.
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A loan in trial modification plan (trial mod) can transit into the following state the next month:

1. Mortgagor payoff: this is an unlikely outcome, as loans in trial mod are troubled loans.
2. Repurchase: Being repurchased out of the pool --- this typically should not happen after giving the loan 3 months in the trial.
3. Forbearance: also unlikely, most loans in trial mod should have used forbearance plan already.
4. Trial Period Plan: loans in trial mod for just 1 or 2 months should stay in trial mod for a least another month.
5. No Plan: trial mod terminated however did not result in a repurchase immediately.
6. Other or N/A: status not available.

The number of loans in these programs continues to grow, standing at 37,957 in February 2022, with a balance of about $8.3 billion, up from 9,911 and $2.1 billion in March 2021. The evolution of the disposition of loans is shown in the following chart: