AISLE submitted a letter to the U.S. Department of Veterans Affairs (VA) on the VA Servicing Purchase Program (VASP) and offered suggested recommendations for consideration. Per the VA Press Release published in November 2023, VASP will allow VA to purchase defaulted VA loans from mortgage servicers, modify the loans, and then place them in the VA-owned portfolio as direct loans.
AISLE’s recommendations were based on the intent to assist Servicers and Borrowers once the program is published. Specifically, requesting tools for mortgage servicers to successfully implement the program once published. Having additional tools once the program is published will ensure a smooth implementation for both Borrowers and Servicers. Below, you will find some of the recommendations for consideration that were referenced:
• Requested the Agency allow mortgage servicers ample time to implement the new program, including recommendations of the following:
• AISLE offered data and general feedback on the note rate, which creates a sustainable monthly payment.
Members can click here to request a PDF copy of the full letter.
AISLE closed its Founding Member opportunity on Tuesday, January 9, 2024, weeks ahead of its scheduled run due to overwhelming interest from the industry. The Institute soft-launched on November 30, 2023, and offered a Founding Member opportunity through the first 24 members or January 24, 2024, whichever occurred first.
"We are exceptionally grateful for the trust placed in AISLE and its mission to shape regulatory policy, first by our Advisory Board members and Cross-Section Leaders. And today, we're thrilled by the response from the industry and those law firms and businesses that have stepped forward as thought leaders intent on shaping the regulatory environment that binds us as collaborators more than competitors," said Co-Founder Cade Holleman, M.A.
Board Chair Marissa Yaker, Esq. added, "As we wrap up our very exciting launch, I am eager to turn our attention to the work ahead of us: focusing our combined energies on regulatory policy, meaningful and impactful change at the agency, servicing, and legal levels, and working to improve the broader housing industry for all market participants."
AISLE Founding Members are listed below, in order of commitment.
Founding Members will have a role in shaping the AISLE Member Code and have a closed-door Founding Members session annually, as well as other membership perks. Additionally, AISLE's initial offering of annual sponsorships sold-out during the same November 30, 2023 to January 9, 2024 window.
Top-level 2024 sponsors at LV4 are a360inc, McMichael Taylor Gray, and LOGS Legal Network. LV3 annual sponsors include McCabe, Weisberg & Conway, Ghidotti | Berger, Quintairos, Prieto, Wood & Boyer, McCalla Raymer Leibert Pierce, and Codilis & Associates. Additionally, Steele, LLP and the Council for Inclusion in Financial Services are LV4 digital sponsors for 2024.
While the Founding Member opportunity has closed, general membership in AISLE is still available to interested law firms and businesses intent on shaping the industry's regulatory environment and operating climate. If you are interested in contributing to the Institute's work on these critical, forward-looking policy improvement goals, you can learn more about how your business can become an important member of the AISLE community by clicking here.
The OCC has published its Mortgage Metrics Report for the Third Quarter of 2023. The Report presents performance data for the third quarter of 2023 for loans that the reporting banks own or service for others as a fee-based business. The data in the report reflects a portion of first lien mortgages in the country, excluding junior liens, home equity lines of credit, and home equity conversion mortgages. For perspective, “the reporting banks serviced approximately 11.8 million first-lien residential mortgage loans with $2.7 trillion in unpaid principal balances. This $2.7 trillion was 22 percent of all residential mortgage debt outstanding in the United States.”
Daren Blomquist, Vice President, Market Economics, Auction.com, and AISLE Cross-Section Leader for Trends + Technology, also reviewed the data noted the below.
"while somewhat skewed toward an inherently less risky segment of the market, this report provides more confirmation that mortgage performance has settled into a more stable, sustainable pattern over the past year as the dust settled from the whirlwind market of 2020 and 2021. Absent of some unforeseen shock to the economy or housing market, I’d expect this pattern to continue in 2024. I will be keeping a close eye on redefault rates, which have now increased for five consecutive quarters and have doubled since the fourth quarter of 2021, when the pandemic foreclosure moratorium ended. If redefault rates continue to rise, it could be an indication that more distressed homeowners who have held off foreclosure in the short term are running out of runway when it comes to avoiding foreclosure for the long term.”
Marissa Yaker, Deputy General Counsel of Regulatory Affairs, Padgett Law Group and Chairperson of AISLE, adds her thoughts on the Report's data.
"as an industry, we have BEEN SEEING LOW DEFAULT RATES, but the re-default data is interesting to track in light of all the loss mitigation that took place during the past few years. Hopefully, these Borrowers can benefit from the additional programs that some of the agencies will be releasing in 2024."
Within the Report, the OCC includes a chart that highlights the Number of Re-Defaults for Loans Modified Six Months Previously Modified Loans 60 or More Days Delinquent Six Months After Modification by State. It is interesting to review, due to all the loss mitigation in light of the pandemic. Some of the key points from the OCC Report:
Summary of Delinquent Loans:
Summary of Modifications:
Link to the OCC Report:
Mortage Metrics Report Third Quarter 2023 (occ.gov)