A Security Design Crisis in the Plumbing of U.S.Mortgage Origination

Nancy Wallace

Haas School of BusinessReal Estate and Financial Markets Laboratory

Fisher Center for Real Estate and Urban Economics

MIT GCFP ConferenceSeptember 28, 2016

1

Background MRAs Pre-Crisis Post-Crisis Conclusions

GNMA/GSE pipeline risks

I Secondary mortgage market is heavily federalized.

I GNMA/GSE securitization volume is now dominated by non-depositorymortgage originators.

• CFPB, HUD and state-level oversight – no stress testing.• Reliance on short-term bi-lateral repo funding.• Short-run risks – covenants on repo, slowing of mortgage refi’s (reduced

fee income), underfunding for servicing advances, other balance sheetfailures.

• Liquidity risks – changes in forward funding markets (hedging costs),repo pricing.

• Systemic risks – Repo runs (short-run triggers and BAPCPA 2005),mortgage fire sales, unfunded rep and warranty guarantees, risk toorigination capacity.

2

Background MRAs Pre-Crisis Post-Crisis Conclusions

Warehouse Lending and Repurchase Agreements

Mortgage Origina-tor: Repo Seller

Warehouse Lender:Repo Buyer

Structured InvestmentVehicle (SIV): Repo Buyer

Borrowers

Mort. Note $ Mort. Note$

Mort.

$

(a) Repo Setup

Mortgage Origina-tor: Repo Seller

Warehouse Lender:Repo Buyer

Structured InvestmentVehicle (SIV): Repo Buyer

Private-LabelSPE or GSE SPE

Private-LabelSPE or GSE SPE

Mort. Note $

$

Mort. Note$

$

Bailee Sale Bailee Sale

(b) Repo Unwind

3

Background MRAs Pre-Crisis Post-Crisis Conclusions

Federalization of Secondary Residential Mortgage Market

(Source: HMDA)

4

Background MRAs Pre-Crisis Post-Crisis Conclusions

Importance of Non-Depository Origination for GSE and GNMA

Securitization

5

Background MRAs Pre-Crisis Post-Crisis Conclusions

Dominant Non-Depository Funding Facility: Mortgage

Repurchase Agreements

I Summary of Contract Features:

• Strict capital and accounting covenants.• Significant roll-over risk (short term maturities).• Often highly concentrated repo buyer exposure.• Risk of haircuts and dynamic margins.• Exempt from automatic stay under BAPCPA 2005 (repo buyer holds

perfected mortgage collateral).• Rep and warranty risk resides with originator (repo seller with little

capital).• Mortgage servicing positions at risk: liquidity needs for advances.

6

Background MRAs Pre-Crisis Post-Crisis Conclusions

Dominance of Master Repurchase Agreements (SIC 6162, 6163,

6798)

7

Background MRAs Pre-Crisis Post-Crisis Conclusions

Outcomes for 2006 Top Forty Originators

8

Background MRAs Pre-Crisis Post-Crisis Conclusions

Repo was/is a Bet on Loan-level Securitization Speeds: Mean and

Standard Deviation by 30 Day Bins

9

Background MRAs Pre-Crisis Post-Crisis Conclusions

Top 2016 Public IMCs are heavily reliant on MRAs

10

Background MRAs Pre-Crisis Post-Crisis Conclusions

Concentrated Repo Buyer Commitments (Not including hedge

funds or foreign banks)

11

Background MRAs Pre-Crisis Post-Crisis Conclusions

Conclusions

I Significant pipeline risk exposure for GNMA and GSEs.

• Dominance of imperfectly monitored bi-lateral repo funding.• Importance of risk segmentation between repo buyers and sellers.

I Non-depository pipeline funding is fragile:

• Pre-crisis mortgage origination funding structures are still dominantespecially master repurchase agreements (MRAs).

• MRA funding structures are vulnerable to: 1) roll-over risk; 2) many otherdebt covenants (especially accounting triggers) – this was a veryimportant pre-crisis problem leading to the collapse of lendinginfrastructure and many firm bankruptcies.

• MRAs have repo status so they are exempt from automatic stay–Warehouse lenders (Repo Buyers) will run when market softens.

• Non-depository warehouse borrowers (repo sellers) have no capital, butthey bear the rep and warranty risk – is this sensible?

12