Flagstar ‘reps and warrants’ deal may be coming with Fannie Flagstar had waived any participation in TARP funding, but took an abrupt 180 degree on that stance with their third quarter results. There is no guarantee the bank will receive any funds, however, and that poses a question as to what the next step may be as Flagstar looks to raise additional capital.
As competitive pressures increase for loan growth, banks may be enticed to ease underwriting standards to expand the loan portfolio in order to generate earnings. As conditions begin to deteriorate, this easing of underwriting standards, if carried too far, causes banks to face increased risk that is followed by rising losses and an eventual tightening of underwriting standards.
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underwriting standards has troubling parallels to the decline in mortgage underwriting standards in the years leading up to the global financial crisis. Indeed, according to a 2018 report, average recovery rates for defaulted loans have fallen to 69 percent from the pre-crisis average of 82 percent.10
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15 The proposed rule states that a "mortgage loan could qualify as a QRM only if the borrower was not currently 30 or more days past due, in whole or in part, on any debt obligation, and the borrower had not been 60 or more days past due, in whole or in part, on any debt obligation within the preceding 24 months.