Reflections on Alt-A

What recession?

Re: Eventually, after the bust works itself out and the economy leaves recession

Think covered bonds.

First?

Maybe, just maybe we will see a turn to "community bank lending". Where for the most part, all FICO aside, a local branch manager will be given small discretionary lending authority w/i a broad corp framework. Getting close to the "customer" might replace impersonal lending.

Think covered mortgages, too

It wasn't that long. Nice job. I enjoy a good moral lesson, and you could have preached that one from the pulpit of the church I attend.

This whole mess is about responsibility to society, aka morality.

I think there is a correlation between low volume on wall street and low volume here; this still must summer?

you could have preached that one from the pulpit of the church I attend

You attend Our Lady of Perpetual Pragmatism?

I hope the post comes across as ethical--I never want to sound unethical--but I didn't intend to preach a sermon.

a kind of "not quite quite" lending will certainly return.

is that supposed to say "not quite prime"?

Are all Alt-A loans of a "stated income" or "no-doc" variety? Is there such a thing as a fully documented Alt-A loan?

Go ahead, let it out, a sermon on reality and the evil, the darkness, but which side are you on? WTF, what about a witch hunt?

So, this is what you were cooking up yesterday, when CR mentioned writing; I better do a word count, and then maybe even read it...

Am I just confused, or does Alt-A not also cover people who have special issues with their underwriting situation such as persons who are either small business owners/self-employed workers or persons paid heavily based on commissions and thus have somewhat unstable incomes? Such persons do not necessarily fit comfortably into a standard underwriting framework but do not necessarily fit into subprime lending either as they may have good credit. Wouldn't some form of above average underwriting be able to be able to identify lending opportunities to these persons at reasonable risks?

Re: "fitting loans into a matrix "

Was this done by phone and with slide rules; don't get me wrong, I image the old ways had less fraud, but do tell...

"You attend Our Lady of Perpetual Pragmatism?

I hope the post comes across as ethical--I never want to sound unethical--but I didn't intend to preach a sermon."

I'm with the more progressive brand of Lutherans. They believe in responsibility to society. They preach about systemic injustice, along with the golden oldies. We have been preached at about the housing bubble and corrupt credit practices in passing.

Learned Our Lessons
LOL

One addendum: I used to be an Episcopalian, and one of the greatest sermons I ever heard on the nature of evil was from a priest who used work as a corporate tax auditor for the IRS ("I saw evil every single day.") Say it, bro!

otiose = superfluous (new one there for me)

Tanta,

You must be feeling well, because this is another tour de force post. Damned if I know how you can make mortgage minutia so damned fascinating...

is that supposed to say "not quite prime"?

No, I meant "not quite quite."

Maybe that's a Britishism.

Lending Fundamentals and Underwriting 124: Back to 1992!

Wonder if we can get Bill back too? Nah.

Is there such a thing as a fully documented Alt-A loan?

Most of them were some kind of "reduced doc," but yes, there were "full doc Alt-As."

Those were mostly 100% financing and/or weird properties (like those non-warrantable condos).

Was this done by phone and with slide rules; don't get me wrong, I image the old ways had less fraud, but do tell...

Punch cards and truth-trees.

Wow, thanks! I finally understand the difference between Alt-A and subprime on a fundamental level.

I clicked the "I want the rest of a VERY long post! And I want it now!" link, but my browser just got stuck at 12%. Is it a huge PDF?

I'm not sure you'll play ball here, but when you speak of the old days, I jump forward to rating models and FICO scores and the recent abuse and fraud that was in the system, which was widespread; I like the term collusion. To wit, the recent rating models seem to still be based on these old days your relating too, i.e, these new models are using old histories of a time when debt and creditworthiness were less volatile and less leveraged.
I like to think this new age of attention deficit/lotto mentality skewed the old data and distorted the payment history statistics which are still related to the new models.

To make a long boring post more useless, I think that after 9/11, as rates were dropped to 40+ year lows, everyone that had a mortgage in America did a refi and as millions of loans were scrambled, someone forgot to re-calibrate the ratings models.... what think dude?

does Alt-A not also cover people who have special issues with their underwriting situation such as persons who are either small business owners/self-employed workers or persons paid heavily based on commissions and thus have somewhat unstable incomes?

If by "unstable" incomes you mean "inadequate to service and retire the debt," then no, these people don't have "special issues." They fail the second C, capacity.

There isn't any way to make a resi mortgage loan to someone without sufficient income to service and retire the debt without a perpetual bubble in home prices.

The whole idea that people with "unstable" incomes should still buy houses is a bubble idea whose time is over. These people can too rent and still be "Americans."

Besides, usually when you look at the credit reports of people who have "good credit" but "unstable incomes," you simply find that they've done OK managing very small amounts of personal debt. We have to get away from this idea that successfully managing a credit card account for a year or two with a $10,000 limit qualifies you to buy a $500,000 house.

Groundhogday - Congratulations, now please go explain this to the OCC!

Tanta,

What is so dishonest about the association of "subprime" and "poor people" is that it simply erases the fact that a lot of rich people have terrible credit histories and a lot of poor people have never even used credit. The "classic" subprime borrower is Donald Trump as much as it is "Joe Sixpack."

Too true! My experience with a NE-based "near prime" lender included the discovery that we had a number of players for the Giants and more than a few celeb rappers on the books.

On risk-layering, I once again have to plunk my money down on properly constructed internal models (that incorporate LTV.) You just shouldn't be able to originate paper where all signs point to "no". The thing is, I don't trust a sales-force (or underwriters too closely aligned w/ sales) to ever keep to such a rule without hard numbers that point out exception rates.

Please note, an Episcopalian is a rich Catholic.

Re: "ts intent was exactly to enable people to catch up on an arrearage and then actually begin to retire debt.
"

This is a new age, where the thought of retiring debt has been reverse engineered into new products like 40 year loans and 100 year bonds.

Nice Work. Thanks.

Tanta,

The whole idea that people with "unstable" incomes should still buy houses is a bubble idea whose time is over. These people can too rent and still be "Americans."

This does indicate that there are interaction effects, though. You face less risk in lending to somebody with an unstable income if they happen to be in a stronger market. The trick, as always, is to have some environmental awareness, in the sense of "what is going on around you". If the market is in a bubble, one can safely presume that it won't last forever. Ergo, you can't stretch nearly as far as the year-on-year figures indicate.

FICO scoring is just an automated and much more consistent way of measuring past credit history than sitting around with a ten-page credit report counting up late payments and calculating balance-to-limit ratios and subtracting for collection accounts and all that tedious stuff underwriters used to do with a pencil and legal pad. I have seen no compelling evidence that FICO scoring is any less reliable than the old-fashioned way of "scoring" credit history.

I disagree based on one criteria alone: performance. Backintheday when we sat aaround with the data ; those loans did fine. It isn't a coincidence that things started going sour at the same time the derived FICO trumped the enumerable source material.

See the bigger picture? Derivative analysis is by definition subject to manipulation. People have made millions gaming the FICO. Their "clients" have gleaned unearned billions from those distortions.

If you see no compelling reason to go back to verified creditworthiness why are we going back at all? Is the recent spate of credit verification futile?

Excellent post (for me) as I never really knew the nuances before. I appreciate the effort!

Tanta-

Since "quite" means "not really" in British, I imagine (and hope) the UK will adopt "quite prime" lending once this crisis is past.

This could be yet more grist for your explanatory mill come next crash.

Maybe that's a Britishism.

i guess. do you mean it in the sense of "thorough"?

BG writes:
Tanta,

...You just shouldn't be able to originate paper where all signs point to "no".

I think I heard a cheer from the operations side

Bacon-

If it is/were a Britishism, "not quite quite prime" would mean "not not really not really prime". I can't help you beyond that.

Re: "I think it will be a long time before lending standards ease significantly, and I think subprime will come back first. But I do suspect we've seen the last of Alt-A for a much longer time.
"

I continue to wonder where cash flow will come from, in regard to banks that are writing off multi-billions. Nonetheless, when you see NAR or real estate hype, many suggest a bottom is in, yet with tighter standards and homes still way over-valued in places, I fail to see how banks will be able to support dividend growth in the future and grow sales without this type of fraud backing them. The covered bond scam is just another way to repackage old debt into new debt, so I'm wondering what the driver will be for the economy, and why people think that housing will turn back into a flippers mkt?

do you mean it in the sense of "thorough"?

No, I mean it in the sense of "not quite prime." It's an ironic phrase.

Derivation: "Quite" has to mean the opposite of "not quite." Therefore "quite" is the real thing and "not quite" is below-grade. If you are "not quite quite" you are nearly there.

Sort of. I thought the phrase was more common than it apparently is. I probably picked it up in a Dorothy Sayers novel, meaning it is dated as well as furrin.

Besides, usually when you look at the credit reports of people who have "good credit" but "unstable incomes," you simply find that they've done OK managing very small amounts of personal debt. We have to get away from this idea that successfully managing a credit card account for a year or two with a $10,000 limit qualifies you to buy a $500,000 house.

The key point there is the price of the house. I'm one of those people with a FICO score of 810 and an unstable income from being an independent contractor. I just barely scraped by via tax returns for a loan on a $175k house back in 2002.

For someone self employed, they can own a home with a traditional loan as long as they are excellent money managers. In the years when you do really well, you pay off all credit cards and the car. You also make sensible choices about what you can really afford based on your "lean" years as opposed to your "good" years. You don't EVER make long term financial decisions based on what you can earn in "good" years, you make them on what you can afford to carry in the "lean" years.

It's the people who are lousy money managers that need to be parted from the ability to get no-doc loans.

If it is/were a Britishism, "not quite quite prime" would mean "not not really not really prime". I can't help you beyond that.

Tanta said "'not quite quite' lending," which according to you would mean "not not really not really lending."

...You just shouldn't be able to originate paper where all signs point to "no".

unless it got you to the finish line...a CLOSING....who cares what happens after that.

Oh yeah...I never forget one time waiting for my car to be serviced I wandered into the showroom and one of the salespeople came up to me and said "pick one, any one, and I will make SURE you drive it home today...."

The effect was not the one intended ( I am assuming) since it became obvious to me that he was all about moving product No Matter What and that it had absolutely nothing to do with incidentals like whether I, say, needed a car, or could afford a car, or had a Driver's License....

It was about moving product, as much and as fast as possible...and less about putting people in securely into housing.

It isn't a coincidence that things started going sour at the same time the derived FICO trumped the enumerable source material.

I have no idea what you mean by "trumped the enumerable source material."

And we started using FICOs regularly in 1996. If that led directly to "things going sour," it did so rather slowly.

You simply have no memories of the days when credit analysis was wholly subjective and--to give a real example that used to go on--a paid-as-agreed credit account with Fingerhut or K-Mart didn't count as much as a paid-as-agreed or even a mildly delinquent Gold Card. Because of the class biases of the underwriter, not for any logical scoring of credit performance.

Rob,

I disagree based on one criteria alone: performance. Backintheday when we sat aaround with the data ; those loans did fine. It isn't a coincidence that things started going sour at the same time the derived FICO trumped the enumerable source material.

Correlation =/= causation. The problem doesn't have much to do with FICO per se (though I'm of the opinion that it's not that hard to do better), but rather with how it is used. FICO only measures historical performance. By definition, it can't deal with income and stability thereof, collateral and the soundness of the market for same, or clever fraud/ identity theft. If a FICO or FICO-like score is used as a proxy for a lot of tedious work looking at bureau printout, it works fine. FICO, or rather, the various FICOs, still rank-order risk quite well. The problem is, you need a person or another, different system to capture market effects, attempted fraud and recent changes in the applicant's status.

Also, higher up, you need somebody paying attention to the trends and applying a sort of meta-analysis. i.e. "2003 vintage looks too good compared to predictions; wonder if it has to do with refinancing bads going into 2004?"

...My point is that even without excessive "stated income" or appraisal fraud, the Alt-A model was essentially doomed

I think the biggest problem with the Alt-A market was the scale. What started out as a niche product for self-employed borrowers exploded into a crazy speculation attracting affordability enhancer.

Like so many mortgages that 'fell into the wrong hands', I would argue that back in the day, no-doc loans existed for a unique and rare yet defensible reasons.

Some small segment of consumers has always been willing and able to pay a premium to keep their finances private, yet aren't quite quite wealthy enough for private banking - Alt-A was created for them. And it was a fine product, back when it was reserved for the likes of B-list celebrities and future beneficiaries of the Federal Witness Protection Program.

It's when Alt-A went mainstream that it served only to hasten the arrival of our latest Minsky moment.

Bacon-

You're right - I misquoted. But the point is the same - there are a couple of different levels of understanding Tanta's joke.

For a better explanation of "quite" among the British:

Dr. Frank's What's-it: Quiteism

Ms Tanta,

What is your professional opinion on the amount of discretion used to fudge valuation metrics, i.e, you have appraisers that can fudge and loan officers that can use discretion and banks that can fudge numbers -- so, in the past, did it seem like there was on-going fudging and nudging and massaging and skewing and bias manipulation, or does this latest era of bubble fraud seem to be out of control?

OT, maybe, maybe not?

The Great Credit Squeeze: How It Happened, How to Prevent Another
here

.. From 2001 to 2003, mortgage originations hugely expanded, with much of the growth from prime conformable loans. After that, the total volume of originations dropped and the share of originations in subprime and Alt-A mortgages increased.

The erosion of mortgage-lending standards stands out as something that could and should have been stopped. The challenge going forward is either to create an appropriate incentive structure within the “originate to distribute” model, or to provide a better and more integrated force of regulators to compensate for the misaligned incentives

Tanta and BG have taken me to task.

And we started using FICOs regularly in 1996. If that led directly to "things going sour," it did so rather slowly.

You simply have no memories of the days when credit analysis was wholly subjective and--to give a real example that used to go on--a paid-as-agreed credit account with Fingerhut or K-Mart didn't count as much as a paid-as-agreed or even a mildly delinquent Gold Card. Because of the class biases of the underwriter, not for any logical scoring of credit performance.

Firstly, I didn't even blanche at the mention of Fingerhut (the original fog-a-mirror credit organization) so I don't think it is fair to say I have no memory of the era. And yes it was mostly subjective including overt racism, sexism, classism and lots of other nasty things that most assuredly had nothing to do with credit worthiness. Still we managed to write fewer bad loans did we not?

As to the speed, yes it was painfully slow. I agree that 1996-1997 represented the turning open of the Great Spigot of Credit. Only time will tell if the Great Unwinding will encompass the entire period but given the recent speed of reversion I wouldn't rule it out. As a metric of this last I suggest we watch the national homeownership rates.

More trash:

Underwriting policies that are
based on FNMA and FHLMC guidance are adhered to for loan requests of conforming and non-conforming amounts. The weighted average
loan-to-value ratio of all residential mortgage originations in 2007 was 59 percent while FICO (independent objective criteria measuring the
creditworthiness of a borrower) scores averaged 747.

FIRREA also imposes certain independent appraisal requirements upon a bankÂ’s real estate lending activities and further imposes certain
loan-to-value restrictions on a bankÂ’s real estate lending activities. The bank regulators have promulgated regulations in these areas.

In addition, significant provisions of FDICIA required federal banking regulators to impose standards in a number of other important
areas to assure bank safety and soundness, including internal controls, information systems and internal audit systems, credit underwriting,
asset growth, compensation, loan documentation and interest rate exposure.

Tanta,

"on--a paid-as-agreed credit account with Fingerhut or K-Mart didn't count as much as a paid-as-agreed or even a mildly delinquent Gold Card. Because of the class biases of the underwriter, not for any logical scoring of credit performance"

I would love a Tanta essay on the class/sex/racial/religious biases of the old approval system. I know there were several cases of blind studies done where equal applicants were treated to different results. It seems like I remember this was major news about 15 years ago.

"The whole rationale for the famous 2/28 ARM was that after two years of good payment history on that loan, the borrower could refinance into a prime loan and thus never have to pay the "exploding" interest rate at reset"

\t
Two years is also the time it takes for a speculator to buy a nascent house and sell it once finished

What is your professional opinion on the amount of discretion used

The "discretion" was in fact what really went away in the Great Bubble.

I mean, if you loosen your "official" underwriting guidelines that much, what do need "discretion" for?

That was my argument in this old post on stated income:

Calculated Risk: What's Really Wrong With Stated Income

For those who want an even more detailed look at the early history of subprime, get the recently published book "Chain of Blame," by Paul Muolo and Mathew Padilla.

The trouble with that assumption was that we were busy building a credit industry in which there was plentiful credit--on easy terms--for people with any FICO, any "reputation."
A huge change was made in the late 80s or early 90s and no one held a news conference to announce it -- and people of a certain age weren't aware that things were changing.

I'm 45. When I was in college, and for a few years after I graduated in '85, credit reputation mattered because you couldn't get a credit card without it. As feckless as I was in my 20s, I was turned down for credit cards and store charge cards and even for "overdraft protection" at a bank. A lot of people my age and older have had experiences like this or they knew someone who it happened to.

Then college students started getting credit cards when they were still freshmen or sophomores. Credit became available to risky people. And I think a lot of folks were unaware of this. In the late 90s and early 2000s, they assumed that, if they were approved for credit, that meant they were creditworthy.

Many people were unaware that borrowers, not lenders, had become the credit gatekeepers. Or, in Tanta's words, that "we were busy building a credit industry in which there was plentiful credit--on easy terms--for people with any FICO, any 'reputation.'"

It's easy to borrow too much, at too-risky terms, if you mistakenly believe the lender is making rational decisions.

When you are a human being, and you are constantly, if tediously going thru someone's credit history, you get the ability to get a hunch that there's just something wrong there. Then you get promoted and your abilities carry foreward with your further analysis. If the human being never gets to deal with the tedious work, the higher up never forms the subconscious habits which allow one's antennae to start wiggling with the info that there's something wrong here.

Yeah, there was racism and sexism (in '72, a friend, who was female was denied a loan because she was female. Her hub who WAS NOT WORKING got the credit, and they didn't even want to put it in her name too.

I saw an S & L go from intending to hold its own loans to intending to sell them and the quality dropped literally within weeks. Place never was automated, was mid 80s, so I must say, that having to hold, say, a percentage of your own loans, with maybe bonuses after 4 years of faithful payment, instead of immediately, would have a benificent effect.

I conclude holding is more important than anything else.

There were large incentives to game FICO scores when it made difference between getting and not getting a mortgage. If collateral and capability resume their traditional importance then the difference becomes being prime or prime- or subprime plus. Not worth the effort especially if attempts to game can result in reducing the credit scores and being moved to subprime plus to subprime when such gamming attempts are recognized.

hol-leeee-k-rap!!

i couldn't do it, tanta, sorry.

I would love a Tanta essay on the class/sex/racial/religious biases of the old approval system.

Maybe some day.

For now, I have to say that it's hard for anyone--even someone who isn't generally full of those kinds of biases--not to react in certain idiosyncratic not very objective ways to reading other peoples' credit reports. These days you have the added problem that monthly checking account statements now tell you a lot more than they used to. You used to see check numbers and dollar amounts. Now that people use debit cards, I can see how often you take the kids to McDonald's or stop at the local liquor store.

I remember a number of years ago standing near a group of women in line for something. One of them was fishing around in her purse for something and her Nordstrom's card fell out. "OOOOOhhhh," says another woman really snottily. "Must be great to be able to shop there!" "I work there," says the other woman.

People being people, they will assume things about having a Nordstrom's card that may well be hard to support with data.

Of course underwriters still see the actual credit report with all the data on it. FICO has not made the data invisible. But it has often challenged an underwriter to justify why her reading of the credit report comes up with such a different value than the automated score does.

Graet post. It appears that we worked in the same vinyards at the ame time. What I never understood other via fraud why anyone would do a no doc on people with a W-2. I also aggree, for the reasons you mentioned, the tools to enable people to recover are used up.

A bad credit history is only a strong deterrent to default when credit is rationed, granted only to those with acceptable reputations, or--as in the case of "classic" subprime--granted only to those with poor reputations but strong capacity and collateral, and at a penalty rate.

The supreme irony in Tanta's quote above being, of course, that those selfsame banks who forgot all about the deterrents to default mentioned therein found themselves in a world of hurt when the wrong Jenga block got pulled.

So how are they attempting to extricate themselves from the wreckage? Why, by queuing up at the window and demanding the same abdication of those pesky "prudent lending standards" and "penalty rates" by their lender of last resort, the FRB.

And the Fed has gone right along. No honor among thieves, indeed.

LL,

When you are a human being, and you are constantly, if tediously going thru someone's credit history, you get the ability to get a hunch that there's just something wrong there.

I don't believe in hunches, I believe in p-values. People have too many natural cognitive biases, and that doesn't even get into bigotry.

After all these years in the biz, I never knew the diff between Alt A and subprime. Thought they were pretty much the same thing.

Thanx a lot.

The GEM mtges of yore did ok. They were mtges which went up 3 % or whatever a year, all of it going to principal. Far as I know those didn't go into foreclosure very much at all, unlike the neg ams which had a dreadful experience, except if you got one just before rates began to seriously fall. I knew one lucky person who did, and her payment went down without re-fi-ing and she had neg am for maybe one year.
Very very lucky.

Since the GEM mtges payed down the principal, if you managed to keep one for even 2 or 3 years, you could re-fi because the principal had dropped noticeably, and the house price had probably gone up, say 10% over the 3 year period. Had those been done with 100% loans we would be in much less of a pickle today. Of course, during that period, people were actually getting raises, unlike today, tho it is doubtful that the raises kept you above inflation. Still the GEM mtges were a form of forced saving, which in the light of all that has happened, is an excellent idea.

Tanta,

That was a good ol post ( SATURDAY, SEPTEMBER 29, 2007):

  1. I have said before that stated income is a way of letting borrowers be underwriters, instead of making lenders be underwriters.
  2. What the stated income lenders are doing is getting themselves off the hook by encouraging borrowers to make misrepresentations. That is, they're taking risky loans, but instead of doing so with eyes open and docs on the table, they're putting their customers at risk of prosecution while producing aggregate data that appears to show that there is minimal risk in what they're doing. This practice is not only unsafe and unsound, it's contemptible.
  3. All those claims by securities issuers and raters about how we had no idea that gambling was going on in this joint are directly comparable. The tough news for the self-employed "respectable" borrower is that I don't care if you're individually willing to play bagholder: you can't afford to underwrite that collective risk.

Holden - when I was in college, my bank, B of A, granted me a credit card with a $200 limit. After one year of perfect payments, they raised it to a princely $300. So yeah, I had the attitude that if a bank gave someone a lot of credit, they were credit-worthy.

I read British murder mysteries too, and when someone says another character "isn't quite quite" they mean not out of the top drawer, not one of us darling. So I can see it ironically meaning not perfect credit history.

Also, I think Alt-A might have worked much better if it had stuck to two-out-of-three. Good credit history and well established ability to pay, or good credit history and extra low CLTV. One out of three was a recipe for disaster if house prices ever even paused, much less went down.

Pity the souls who did not get to this gem - beautiful job, Tanta:

"You're probably still wondering what all this has to do with Alt-A. Alt-A is sort of a weird mirror-image of subprime lending. If subprime was traditionally about borrowers with good capacity and collateral but bad credit history, Alt-A was about borrowers with a good credit history but pretty iffy capacity and collateral. That is to say, while subprime makes some amount of sense, Alt-A never made any sense. It is a child of the bubble."

"Obviously the whole thing was ultimately built on the assumption that house prices would rise forever and there would always be another refi."

My sense is that folks not always thought they could refi, but they just didn't think at all. Home prices were rising and they were afraid they would be left behind or never be able to afford a home; just more instant gratification.

People have made millions gaming the FICO.

That's why retrospective analysis doesn't work very well in this type of industry. Retrospective analysis works because nobody at the time knew what they would be measured on. Nobody was actively trying to boost their scores by meeting criterion A, B and C. Once people found out what they were scored on, they started to game the system and FICO scores were inflated. All of the sudden people don't have high FICO scores because they are creditworthy, but because they know how to make it look like it.

Two comments:

Rob Dawg writes: Derivative analysis is by definition subject to manipulation. People have made millions gaming the FICO.

Though counter-intuitively, it was people with low FICO scores that were the most sought-after near the end of the bubble, as they gave the best yields needed to goose the CDOs. If there was a push for the predatory lenders, this was it.

Tanta wrote: There was also the assumption that people are emotionally attached to their FICO scores--in more old-fashioned terms, that borrowers care about their "reputation" and don't want to ruin it by defaulting on a loan.

Even if true, it also depended on their debt shrinking so as to not find the inevitable "default point" that all people have. Further, toss in shrinking collateral value, shake well, and add an olive. Ummmm... tastes bitter.

Thanks Tanta. As always, your writing and insight is excellent and intelligent.

Post WWII a majorty of less than prime lending was done through the VA loan progran and is one of the great success stories of government.

Too bad a higher percentage of the population today never served in the military--a lot of these terribly crappy loans would have never been made. The California Department of Veterans Affairs will still lend up to 521K @ 6.2% fixed, 97%LTV.

Ignorantia juris non excusat or Ignorantia legis neminem excusat

Ignorantia juris non excusat - Wikipedia, the free encyclopedia

Re: What the stated income lenders are doing is getting themselves off the hook by encouraging borrowers to make misrepresentations. That is, they're taking risky loans, but instead of doing so with eyes open and docs on the table, they're putting their customers at risk of prosecution while producing aggregate data that appears to show that there is minimal risk in what they're doing. This practice is not only unsafe and unsound, it's contemptible.

Holden Lewis said:

"Many people were unaware that borrowers, not lenders, had become the credit gatekeepers. Or, in Tanta's words, that "we were busy building a credit industry in which there was plentiful credit--on easy terms--for people with any FICO, any 'reputation.'""

I can't help but think this might have been in relation to the bankruptcy reform (Bankruptcy Reform Act of 2005) - Wikipedia, the free encyclopedia. If debts are harder to discharge, the penatly of overloading a consumer with debt is disminished. Heck, it the debt can't be discharged, why should the lender be a garekeeper at all?

At least until too many consumers fall victim to debt servitude and the political winds start to change.

Heck, it the debt can't be discharged, why should the lender be a gatekeeper at all?

Practically speaking, I understand that it is still impossible to squeeze blood from a stone. Not that I've tried, myself, but still....

The lender always has a reason to maximize profits by minimizing charge-offs as compared to interest income. That holds whether the debt is technically dischargeable or not, or secured or not.

Wonder what your opinion is on Fair Housing Laws, Community Reinvestment Act and being 'mau maued' by local activists have had on the issuance of loans to people who otherwise might not have gotten them.

I recall an article in the San Jose Mercury News that noted 2/3's of the foreclosures in that city were on people with Hispanic surnames. Roughly twice the percentage that would obtain if things were 'equal'.

I see this in my own work ( a utility) where delinquency rates are higher within a certain ethnic population and it doesn't matter the income level of the neighborhood. The result is the same. More delinquent accounts. Can't say or do anything about it of course except eat the losses and pass them on to the rest of the customer base but that rest of the customer base is getting thinner and thinner due to demographic changes.

We are in the era of management by EIEIO ( Everyone Is Expendable In Organizations). If people with "unstable" incomes should be renters, this begs the question of who precisely has a stable income anymore?

Excellent post Tanta. I read every word. My favorite part is this:

The utter fraudulence of the whole idea of Alt-A involves the suggestion that people who have managed debt in the past that was offered to them in the past on conservative "prime" terms must therefore be capable of managing debt in the future that is offered to them on lax terms. FICOs or traditional credit analyses are good predictors of future credit performance, but only if the usual terms of credit-granting are similar in the past and in the future. Think of it this way: subprime borrowers had proven that they couldn't carry 50 pounds, so the subprime lenders found a way to restructure their debts so that they were only carrying 40. Alt-A lenders took a lot of people who had proven they could carry 50 pounds and used that fact to justify adding another 50 pounds to the burden.

This has not worked out well.

"One of the main reasons we are in a mortgage credit crunch is that two possible models of "recovery" lending--subprime and Alt-A--got used up blowing the bubble. I think it will be a long time before lending standards ease significantly, and I think subprime will come back first."

This a key point. During recovery lenders have always made "subprime" or substandard (as in Alt-A) loans to purchasers of REO as "loans to facilitate." This time lenders made LTF loans too, only this time the loans facilitated the creation of an REO, not the liquidation of one.

The buyers of last resort that normally fuel the recovery have already been tapped. And are tapped out.

The "original" alt-A loan was one made to a borrower who had a decent credit history, but who had "alternative" income sources not easily verifiable. The "mitigant" to verification for alt-A lending way back when was... a big down payment -- usually well over 20%. Recall that "alt-A" used to mean an A credit but where the borrower didn't meet the specific underwriting guidelines of the GSEs.

The first "blowup" of alt A lending that I recall was back in the late 80's/early 90's, and the catlyst for the blowup was, in essence, "appraisal bias/fraud"; that is, the property appraisals on some of the loans were, let's just say, a bit inflated. My recollection is that Citimortgage got burned badly on such lending.

It's not easy to pinpoint how alt-A lending went from "other mitigating factors" (again, mainly large down payments) to a FICO driven definition, but the major catalyst appears to have been "models" driven by default behavior during the "no housing market went down" years from the late 90's through around 2005. When home prices are rising (almost everywhere!), a major driver of defaults appeared to be related to how well folks managed their finances. The ratings agencies in 2004-05 shifted their models to placing much greater weight on FICO and much lesser weight on down payments/other, as that is what "the data" during "good times" suggested. Any seasoned mortgage analyst knew at the time that modeling defaults with data available only during "good times" was fraught with danger.

As Poison said in their classic song from 1990 (which I believe was inspired by a surge in defaults from so-called "alt-A" loans back then:

"Well my vices have turned to habits
And my habits have turned to stone
The lies chipped away at my smile now baby
While the truth ate me down to the bone
One more step and I swear
I'll be over the edge
I've gotta stop living at a pace that kills
Before I wake up dead
Chorus:
Good times, bad times
How life loves a tragedy
Heartbreaks, heartaches
How life loves a tragedy"

Hope that helps!

Good to have you back Tanta. Smile

To think that some of the most interesting writing done today is found on a finance blog, in posts that cover the minutiae of the mortgage business. I can no longer read the fiction in the New Yorker (or much else besides Anthony Lane) without gritting my teeth, but I would never miss a Tanta post.

I'm reminded of Auden's letter to the Nation about James Agee's movie reviews:

Dear Sirs:
In the good old days before pseudo-science and feminism ruined her, it was considered rude to congratulate one's hostess on her meals, since praise would imply that they could have been bad, and by the same courtesy it should be unnecessary to write grateful letters to editors. Astonishing excellence, however, is the exception, and James Agee's film column seems to this reader, and to many others he has spoken with, just that.

I do not care for movies very much and I rarely see them; further, I am suspicious of criticism as the literary genre which, more than any other, recruits epigones, pedants without insight, intellectuals without love. I am all the more surprised, therefore, to find myself not only reading Mr. Agee before I read anything else in the Nation but also consciously looking forward all week to reading him again. In my opinion, his column is the most remarkable regular event in American journalism today. What he says is of such profound interest, expressed with such extraordinary wit and felicity, and so transcends its ostensible--to me, rather unimportant--subject, that his articles belong in that very select class--the music critiques of Berlioz and Shaw are the only other members I know--of newspaper work which has permanent literary value.

One foresees the sad day, indeed, when Agee on Films will be the subject of a Ph.D. thesis.

W.H. Auden
Swarthmore, Pa., October 16, 1944

@Tanta
I have to disagree with the following:

A lot of folks see the failure of Alt-A as a failure of FICO scores. I don't see it that way. FICO scoring is just an automated and much more consistent way of measuring past credit history than sitting around with a ten-page credit report counting up late payments and calculating balance-to-limit ratios and subtracting for collection accounts and all that tedious stuff underwriters used to do with a pencil and legal pad. I have seen no compelling evidence that FICO scoring is any less reliable than the old-fashioned way of "scoring" credit history.

Rob Dawg said it pretty well, so I am not going to repeat what he said. I will clarify one of his statements though:

It isn't a coincidence that things started going sour at the same time the derived FICO trumped the enumerable source material.

more specifically:

FICO trumped the enumerable source material

Means that the work derived solely from the source is considered of greater value and accuracy than the original data points.

In reality, every derivation always adds noise and inaccuracy into the 'derived' data.

On a side note: doing the long hand work including reserve calculations etc is no longer so tedious now that computers are available.. just stop using them to play games for a bit.

A FICO score can't show:
Debt to Equity ratios,
Debt service costs to disposable income,
ability to handle debts greater than a credit card payment,
why the debt was incurred (which could show poor planning and poor reserves)
While some of that is recorded on a FICO, not all of it is.
FICO relies too heavily on credit card debt and records, which is contrary to identifying someone who can handle mortgage payments reliably. If you have a moderate amount of spare cash at the end of the month, why do you 'need' a credit card? The fact that you have the spare cash would indicate that you might be managing your expenditures so that you don't run out at the end of the month.

In closing off, I am going to explain my scenario:
*Liquid assets approaching 7 digits (I don't count anything less than $1)
*Easily able to pay cash for items over $1000.-- I don't have use the credit card to delay the payment until more cash comes in.
*Have bill payment records in excess of 10 years showing reliable payments.
*Salary over $100k.
*Have had a corporate credit card for over 10 years - any monthly bill is paid immediately and not allowed to 'ride'.
The clinch:
I tried pulling my credit scores, all of the credit agencies go .. 'huh?'.. basically they don't know me because I don't have debt and don't carry debt.

Personally, not being able to pull credit scores on myself doesn't bother me too much because I don't need it.. except for a mortgage. Considering that identity theft is centered around credit scores and my name is almost as common as 'Dave Smith', I am not bothered by the inability to pull a FICO... except again, it is one of the primary determinations for a mortgage, of which FICOs are not that great a predictor of the reliability of that payment. You need to compare apples to apples and oranges to oranges.

With credit cards, you are looking at carrying a debt amounting to between 0 and 30k on depreciating assets that don't have an ability to shelter income from tax.. in other words, non-producing bad debt.

With mortgages, you are looking at carrying a debt amounting to over 300k, sometimes millions on an asset that is a decent inflation hedge and the interest has the ability to shelter income from tax.. in other words a producing, potentially good debt.

People who know how to manage money well, learn to avoid the bad debt and use the 'good' debt to their advantage. Because FICO's overemphasis on credit card debt, it does not pick up the subtle but important distinction.

BG: You face less risk in lending to somebody with an unstable income if they happen to be in a stronger market.

How long does the loan last? How long does that compare to the "strength" of the local market?

The SF Bay Area, where I live, is usually considered a strong market. It collapsed in the early 1990s, it's collapsing now ("real Bay Area" diehards aside). If Strong Markets are going to have a collapse every 15 years, then shouldn't 30-year mortgage lenders assume two market collapses, and analyze capacity accordingly?

Not to mention that, I think, Tanta's post already covered this point under "hard money". The suggestion, as I read it, is to lend based largely upon collateral.

ucodegen,

You have a lot there, much of which I don't disagree with. However, you made one statement which is basically incorrect.

one of the primary determinations for a mortgage, of which FICOs are not that great a predictor of the reliability of that payment

FICO scores (and there are multiple models and sub-populations which they were specified off of) generally do rank-order credit risk quite well, including mortgage risk. Note that I said "rank order". That means that a 700 will, on average, pay better than a 600. That's regardless of market factors, the general economy, the local economy or anything else. What is less stable is the actual level of defaults and losses that you will see associated with any given score-band. That varies a great deal based on all those exogenous factors.

As an aside, I'm fairly surprised that you lack a score. Even a very limited installment loan history is usually enough to generate a number. The real problems are with "thin" files where the depth of history doesn't give a lot of confidence in the number and with the "under-banked population".

Tom,

If Strong Markets are going to have a collapse every 15 years, then shouldn't 30-year mortgage lenders assume two market collapses, and analyze capacity accordingly?

Yes! Smile To expand, a proper analysis would incorporate long-term trends and deviations from them.

Not to mention that, I think, Tanta's post already covered this point under "hard money".

I think I'm talking about something more subtle than hard-money lending. That relies almost entirely on the idea of a repo and a "recovery" in excess of what was borrowed. I'm just saying that you need to adjust the risk on even prime loans with low initial LTVs for market conditions. Some percentage of even super-prime paper will default, and recoveries will vary strongly based on market conditions, which is exactly what we're seeing today.

Wow, Tanta! Many thanks for this informative, fascinating post. I've been in the mortgage industry for five years, but in IT, so I understood neither the detail nor the historical perspective you laid out here.

Like others here and in the later thread, I was wondering about the portion of Alt-A that went to people without jobs that give them nice, consistent W-2s, but you've answered those questions nicely as well. I still wonder, though, if the industry can long resist that market as you imply at the end of your post:

I think it will be a long time before lending standards ease significantly, and I think subprime will come back first. But I do suspect we've seen the last of Alt-A for a much longer time.

I remember origin of Alt-A loans a little differently. 1. Alt-A was a loan product designed for borrowers who didn't want to or couldn't fully document their income. They paid a higher rate, maybe lower LTV. 2. Alt-A was a loan on a non-traditional property, think mixed-use 3 story in a NYC borough, retail on first floor, 2 residential units above. In theory and actually in reality (at least for a while), both of these kinds of Alt-A loans made perfect sense. Investors earned a higher rate than GSE-product fow what was perceived to be taking on acceptable risk. However, as is the case with almost all "new" loan programs, sales people immediately go to work "bastardizing" the loan product and generally their managers are too weak to stop the practice. The Option ARM is another example of a very intelligently designed and innovative loan product - great for a certain profile of client - financially sophisticated, financially literate, upwardly mobile. When mgmt allowed sales people to turn the Option ARM into an "affordability product", the gig was csoon to be up. Shoehorning financially illiterate, blue collar folks into an Option ARM was a failure of Mgmt.

I think the biggest problem with the Alt-A market was the scale. What started out as a niche product ... exploded into a crazy speculation attracting affordability enhancer.

Double-ditto for Option ARM. Near as I can tell, it was all about gaming the reported DTI.

@BG
You have a lot there, much of which I don't disagree with. However, you made one statement which is basically incorrect.

one of the primary determinations for a mortgage, of which FICOs are not that great a predictor of the reliability of that payment

FICO scores (and there are multiple models and sub-populations which they were specified off of) generally do rank-order credit risk quite well, including mortgage risk. Note that I said "rank order". That means that a 700 will, on average, pay better than a 600. link

I'm not going to quote the whole reference.. hopefully the link works.

I strongly disagree. It is down to the nature of the debt as well as the nature of how the FICO score is generated and can be 'gamed' by credit fixing.

A FICO score can be 'fixed' by establishing credit through credit cards, and a payment history through the cards. It is not established through paying bills on time (unless you use the credit card to pay off the bill and then pay off the credit card - basically debt shuffling.). This is contrary to someone who has been able to manage debt well, or completely avoid it. FICO scores show the ability to shuffle debt.. and I'll explain.

FICO worked while the housing ATM existed. This is because the eventual source of funds to cover credit debt tended to be a refi. This has been workable for close to 10 years. The problem now is that the housing ATM is closed and the debt really has to be paid off, not shuffled to the eventual HELOC or refi. Just because house prices went up for nearly 10 years does not mean they will continue. Just because the FICO worked under the house ATM does not mean it is a good predictor of loan success. Analyze why it failed this time..

As an aside, I'm fairly surprised that you lack a score. Even a very limited installment loan history is usually enough to generate a number.

The problem is that it never really gets to the 'installment' state because I can pay it off easily without resorting to carrying it. This is fundamentally the argument I am making. You have to be in a financial state/state of mind that you would use debt that is not beneficial to long term financial success to be able to get a FICO score. This is contrary to someone being able to carry a mortgage. It only relates to how well they can 'juggle the balls'. When real global financial stress occurs.. FICO fails badly - note the 2x increase in prime defaults we are now seeing. The skillful jugglers are starting to fail. What really matters is the underlying financials, which FICO misses. A mortgage loan should really be evaluated much like a corporate bond.. which it is really much like. Both are secured by the underlying assets of the home or corporation. Both generally have first order of succession in bankruptcy. Wage pays the mortgage and corp income pays the bond.

There were many situations where people had a good FICO, but poor savings. This should have been a warning. A person in this state is just barely juggling the debt and has never really gotten out from under. They should also review their spending habits.

What should really matter is how much savings they should have been able to manage and over what time period related to their income. What is the consistency of increase in savings and over what time period? This shows restraint in the spending department. Reliable bill payment should also be considered, but not necessarily related to credit card billing. Watch out for transfers of regular monthly bills to credit cards because this shows poor planning for expenses.

FWIW I'm British and understood "not quite quite" as meaning "definitely not good enough, but we don't want to say so." I wouldn't say it, but Dorothy L. Sayers or some of her characters definitely would. It expresses a deliberate vagueness or an affected disfluency, used to avoid taking possibly-impolite explicit notice of obvious facts.

Tanta writes beautifully.

"not quite quite" was vaguely familiar to me, and I took it in the same way as Eleanor.

This book of Catch Phrases has a nice definition, with the "not quite quite" entry nestled in between "not on your nelly!" and "not so green as I'm cabbage-looking":

Shorter dictionary of catch phrases - Google Books

ucodegen,

We'll have to agree to disagree. I've got data on loan performance in '07 and up-to-date performance on others that show FICO still strongly rank-ordering default risk. (Not mortgage, but much of it secured, FWIW) YMMV.

We'll have to agree to disagree. I've got data on loan performance in '07 and up-to-date performance on others that show FICO still strongly rank-ordering default risk. (Not mortgage, but much of it secured, FWIW)

If you can, look at the dollar amount involved. I am assuming, maybe wrongly, that these secured non mortgage loans may be car loans(purchase money)? It will be interesting to see how these pan out as the housing ATM's halt ripples.

If they are car loans, it would be interesting to find out if they correlate fairly strongly to FICO. My reasoning is as follows:
*With credit cards, a bad credit card report will cause a ripple through the card limits and fees.
*A bad car finance report will do the same.
*Amounts on limits between total credit card debt and car finance costs is fairly similar, mortgage significantly different.
*credit card debt and car purchase debt is similar in that they involve both depreciating assets bought with borrowed money - only diff is one is secured and the other is not.

With the housing ATM stopping the juggling act, it will be interesting to find out if these people start defaulting on everything else and the once nearly pristine credit goes to pieces (beyond just the mortgage). I don't know if it is possible to follow 'anonymized' individuals through these changes.

From what I saw down in the street. There was too much bouncing the credit around and then when it got too expensive to maintain, refi and roll it all together in a new mortgage - presto, lower rate and clear cards... all it would do though is postpone the inevitable.

The stopping the house ATM was the tipping point. Cards start defaulting, cars getting repossessed etc.. but from the FICO, whocouldaknown it would happen. Of course, as the cards start defaulting etc.. the FICO score goes in the trash.

PS: Part of this is coming from inside info on two people with about 780 FICO. The housing ATM stop is causing a problem. One has enough reserve so they don't have much of a problem. The other doesn't have a reserve and they were planning to refi in about 4 to 5 years 'to get the monthly cost down'. They are presently in an IO.

I do know that two does not make a trend, but when a 'standard' for evaluating breaks, it is worth figuring out why.

It is like in statistics. You can have a correlation that for some reason just breaks periodically. In my opinion, this is the FICO ratings. You can accept that or step back and figure out why it broke. In statistics, this could be that you are actually using dependent variables instead of independent, and the independent variables have not be quantified in the correlation or not all of them are present. FICO is derived from behavior driven by fundamentals. If you look at the fundamentals, you see the real reason the correlation breaks. FICO misses those that would be good mortgage credit risks because they run little debt and misses those that will default because they were using the home ATM. FICO sort of works, until it breaks. When it breaks, it is spectacular because it is missing several of the independent variables and the values for them just changed.

This gets us back to Rob Dawg's comment:
It isn't a coincidence that things started going sour at the same time the derived FICO trumped the enumerable source material.

The enumerable source material is debt equity ratios, wages and how the person has really been managing debt.

My thanks for the education I've gotten from Tanta, ucodegen, Thomas Lawler, and other commenters above.

One complaint I have about Tanta's view is that she sees too much deviance in the lenders (e.g. she uses the word "fraud" four times in reference to lenders). An old saying of the wise is "never ascribe to malfeasance what can be explained by incompetence".

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