Image by Tessa Hunkin 

Fannie Mae’s new Loan Quality Initiative adds a number of new quality control requirements for originators that must be in place by July 1, 2010.  Perhaps the biggest change is the new requirement for all originators to perform pre-funding quality control reviews, in addition to the existing requirements for post-funding and early payment default (EPD) reviews.  For mortgage quality control professionals, this is another step toward what we at Cogent call “Enterprise QC” — an integrated, end-to-end approach that promotes continuous QC monitoring of all loan origination and servicing processes.

Until now, most lenders have had a disjointed and incomplete approach to quality control across the enterprise. Even among lenders that have been doing some form of pre-funding review, the results are often not available to post-funding reviewers, because there is not a common database for sharing the information.  Although many lenders have begun using automated compliance engines (ACE’s), such as those provided by Mavent and ComplianceEase, the loans that are flagged by the ACE for potential compliance errors are not automatically targeted for post-funding reviews. And QC auditors doing reviews of EPD’s, Repurchases and Claim Denials often do not have access to the data from the pre- and post-funding reviews. On the servicing side, many lenders still do not have a formal quality control process in place, and those that do often do not have access to data from other servicing department audits, let alone audits of originations.

We believe the keys to successful Enterprise QC are: (1) the ability to easily access and manipulate the production and servicing data that are needed to accurately define the populations and select the loans that qualify for each quality control audit, (2) continuous communication between quality control managers and the managers of the processes being audited to ensure that audit checklists always reflect the most current policies and procedures; (3) closed loops for reporting, feedback and response, to ensure that adverse findings are responded to and corrective actions are implemented and documented; and (4) sharing of all quality control data across the enterprise, to maximize the returns from the risk information generated from each QC process.

It’s been no surprise to see a flood of books aiming to unravel the causes of the financial crisis of 2007-2009.  By many accounts, Gregory Zuckerman’s “The Greatest Trade Ever: The Behind-the-Scenes Story of How John Paulson Defied Wall Street and Made Financial History” is the best of the bunch.

Now Michael Lewis, one of our favorite financial authors, has thrown his hat into the ring and released “The Big Short: Inside the Doomsday Machine.”  Lewis is one of the most engaging writerss working today, with a particular flair for apt analogies and clear phrasing (“A credit-default swap was confusing mainly because it wasn’t really a swap at all.  It was an insurance policy…”)

By weaving compelling characters into his narrative, he manages to entertain while informing.  No mean feat.

For a taste of Lewis’ latest, check out the long excerpt in Vanity Fair.  You’ll see that it reads like a thriller and crystallizes a lot of the thinking that’s surrounded this epic debacle.

(By the way, note the interesting phenomenon on Amazon’s customer reviews of the Michael Lewis book.  Almost every one-star rating bemoans the lack of a Kindle version of the book, not the actual content of the book.)

The title and central theme of this blog is “return on quality”, which we broadly define as the benefits to be gained from an intelligent and continuous approach to improving mortgage loan quality.

We said in an earlier post that we would try to formulate “return on quality” and as a step in that direction, we offer a Cogent white paper called “Quality Performance Benchmarking” that was originally developed for an audience of mortgage quality control professionals.

Image by jacob earl

In this paper, we talk about the prevalence in the mortgage industry of a production maximization mentality, in which metrics and compensation are centered on volume; the potential hazards of this mentality; guidelines for estimating the costs of poor quality, (the inverse of the return on quality); how to reward good quality; and how to craft appropriate performance metrics, or benchmarks.  The second part of the paper talks in depth about one of the most powerful tools for benchmarking performance, control charts.

This white paper was written in 2002.  Nothing has changed in the methodology.  But in the last couple of years, the eyes of most of us in the industry have been opened to the dangers of focusing exclusively on volume, volume, volume.  We welcome your comments.

Ocwen Financial Corporation, which does residential and commercial loan servicing, special servicing and asset management, is reporting significantly better results in its HAMP modifications than the rest of the industry.  And they attribute it to superior technology.

In congressional testimony, Ocwen’s President Ronald Faris claimed:

• that Ocwen is converting trial modifications to permanent modifications at a rate that is 10 to 20 times greater than industry average;
• a 3-month re-default rate of less than 5% for Ocwen, versus 18.7% to 33.7% for the industry; and
• a total of 100,000 successful modifications since the beginning of the mortgage crisis.

These impressive numbers could use a little clarification.  So could the statement that Ocwen has spent “$100 million in R&D to build loans servicing technology that incorporates behavioral science for effective customer communication and is also scalable for high volumes.”  But Ocwen is an industry leader and when they report these kinds of results, it’s worth listening.

Image by sgrace

Likewise, their recommendations for improving the HAMP program carry weight.  Among those:

• Lower the borrower debt-to-income (DTI) ratio for modifications to below 31%; in other words, allow for lower monthly payments on modifications
• Allow for principal reductions on modified loans
• Make additional funding available for housing counseling groups
• Require underperforming servicers in HAMP to outsource to servicers that perform

Also worthy of note: Mr. Faris is one of the few industry voices who believes that HAMP is a “well designed response to the mortgage crisis”.  Maybe he’s on to something.