Don't think the gap between the haves and have-nots is widening? USA Today reports the world's richest 1% of people control over 50% of total global wealth. At the other end of the scale, here in the States research by Epiq Systems Inc. finds the top 5 states with the highest bankruptcy filing rates per 1,000 people in order are TN (5.17), AL (4.83), GA (4.66), IL (4.22) and MS (3.69) versus the national average of 2.39.

When it rains it pours for Ocwen. Amy Swinderman reports that the mortgage company is out of compliance with stock exchange listing rules, and that the "Embattled Ocwen spinoff has twice missed deadline on financial reports with SEC. Mortgage servicer Home Loan Servicing Solutions, a spinoff of Ocwen Financial Corp., has fallen out of compliance with NASDAQ's rules for continued listing on the stock exchange after twice delaying the filing of its 2014 annual report with the U.S. Securities and Exchange Commission. Nasdaq Listing Rule 5250(c)(1) requires timely filing of all required periodic financial reports with the SEC, but HLSS has delayed filing twice, saying it needs more time to prepare its Form 10-K filing "related to its ability to operate as a going concern and to provide such information to the auditors for the purposes of their audit of the company's financial statements." HLSS has until May 18 to submit a plan to regain compliance. The company said it will either file its Form 10-K or submit a compliance plan to NASDAQ by that date. If NASDAQ accepts HLSS' plan, it may give the company an additional 180 days from the Form 10-K's due date, or until Sept. 14, to regain compliance. But if NASDAQ rejects the plan, HLSS has the opportunity to appeal that decision to NASDAQ's Hearings Panel."

For those playing along at home, Ocwen spun off HLSS in 2010 to acquire mortgage servicing assets including servicing rights, rights to fees and other income from servicing loans. After announcing its plan for an initial public offering in 2011, the Cayman Islands' HLSS raised $186.2 million in its IPO in 2012. In February, HLSS agreed to sell the company to New Residential Investment Corp. for $1.3 billion, or $18.25 per share, in an all-cash deal. HLSS CEO John Van Vlack said the deal, which is expected to close by the end of the second quarter, would address the "uncertainty associated with our future financing obligations." And Ocwen has been selling off chunks of servicing, including $9.8 billion in servicing rights to Nationstar Mortgage Holdings Inc. in February as part of an overall overhaul of its business. On March 18, it announced an agreement to sell $9.6 billion in Freddie Mac loan servicing rights to Green Tree Loan Servicing LLC.

Ocwen has reached another agreement with Nationstar Mortgage to sell a servicing portfolio on $25 billion of loans, as CEO Ronald Faris shrinks the company amid a mountain of regulatory issues. The portfolio includes 142,000 performing loans owned by Freddie Mac. As noted above in February Ocwen agreed to sell $9.8 billion worth of mortgage servicing rights to Nationstar.

Research firm Compass Point observed, "Ocwen issued a press release announcing the receipt of a deficiency letter regarding its listing status on the NYSE and a delay of their 10-K filing indefinitely. In the following note, we provide our initial takeaways on the items disclosed in the release. We expect the market to react negatively to the release as the additional filing delay adds further uncertainty surrounding OCN's recent operating performance and financial health, while the statement by OCN that it was evaluating its ability to operate as a going concern will also increase investor concerns. As stated in a note published earlier, we believe the most likely outcome will be the acquisition of Home Loan Servicing Solutions (HLSS) by New Residential (NRZ) primarily due to improved access to funding. This will alleviate the near-term concerns about HLSS and its ability to fund advances on OCN's servicing portfolio."

Ocwen, of course, is not taking this sitting down. It recently sent a letter of rebuttal to Trustees and Master Servicers for 119 residential mortgage-backed securities trusts in response to a notice of alleged non-performance issued on January 23, 2015 by Gibbs & Bruns LLP. The notice is the latest effort in a long campaign by BlackRock Financial Management, Inc., Pacific Investment Management Company LLC (PIMCO), Kore Advisors, L.P., Metropolitan Life Insurance Company, and Neuberger Berman Europe Limited to try and impose changes to standard servicing practices, with the goal of forcing more home foreclosures and fewer loan modifications.  The allegations in the notice are substantially the same claims that were refuted during a failed attempt to prevent Ocwen from acquiring a competitor's servicing portfolio in 2013.  Those allegations were ultimately dismissed after being found to have no merit by independent experts. For those wanting to read the official release that covers key points from Ocwen's rebuttal letter, as well as a link to the full letter, here you go: Rebuttal Letter to Trustees.

Let's take this opportunity to play some catch up on somewhat recent lender, investor, and agency changes to sniff around at what's going on out there in the primary markets!

In Freddie news, on March 23 Home Possible Advantage went live and opened the door to 97% LTV Freddie Mac loans for no-cash out refis as well as home purchases. The guidelines even allow gifts to cover the entire down payment, making this a serious option for young homebuyers with limited funds for a borrower contribution. Here's the link to the PDF for HPA. And here is a link to EVP of Single Family Housing Dave Lowman's column on the subject.

Speaking of agencies, for those that missed it in late January the Department of Veteran's Affairs has issued Circular 26‐14‐29, Change 1 - which clarifies when a lender must provide amended copies of a purchase contract to the VA Appraiser.  If the purchase contract is amended subsequent to the effective date of the VA appraisal, but prior to closing, the lender must determine whether the amendment could reasonably be thought to affect the estimated value of the property.  If so, the lender is required to forward a copy of the amended contract to the VA appraiser for consideration.  The VA appraiser will determine the impact (if any) on the appraised value and reply with comment and/or changed valuation (if applicable).  In certain circumstances, the VA appraiser may elect to charge a fee for this service (which is to be passed on to the veteran), depending upon the amount of me and/or extent of any change to the contract that results in additional research or work for the appraiser.  Disputes in regard to any such fees should be referred to the Regional Loan Center (RLC) of jurisdiction. Common changes that should be escalated back to the appraiser for reconsideration include (but are not limited to) a change in seller concession/credit amount, change in sales price, inclusion or exclusion of property, lot size changes, etc.   

And Ginnie Mae posted "Notes and News" regarding Issuer Operational Performance Profile (IOPP) Tool designed to advance monitoring and feedback capabilities. For details, click here.

On the community efforts front, recently Chase announced that 20 small businesses will each receive $150,000 Mission Main Street Grants® to help them thrive. Representatives from the 20 grant recipients received a trip to premier sponsor, Google's headquarters in California for an exclusive small business marketing workshop this month. Google will also provide a Chromebook Laptop computer and a $2,000 coupon toward one market research study with Google Consumer Surveys. Chase's grant program provides an opportunity for 20 small business owners to take their businesses to new heights by receiving an equal share of $3 million in grant funds. Also, all eligible applicants received access to a free marketing toolkit containing useful information and assets to help them promote their small businesses more effectively. To read the press release in its entirety, click here.

Early last month Stearns Wholesale Lending revised its lock terms on Forward Lock Refinances and starting February 2 New Forward Locks on Refinance transactions were subject to a 45 day lock duration price. "Although, the 30 day lock option will still be available in SNAP, the price for a 30 day lock will be the same as a 45 day lock via a Loan Level Price Adjustment. Approved Floating Refinance loans are eligible for a 14 or 21 day lock. Brokers will still have the option to select a 30 day Forward Lock on Purchase transactions."

Stearns NEW Government Incentive Program has introduced a new 25 bps improvement on all government purchase and refinance loans with Stearns. To learn more, click here. 

Back in January Titan Capital Solutions removed maximum cash back limitations on cash-out refinance loans. Loan amount, LTV, and DTI restrictions still apply, as outline in the TCS Product Profile.

Citi Correspondent Lending began requiring all borrowers to SIGN BOTH the initial (prior to underwriting) and final (prior to or at loan closing) HUD Form 92900-A Application Addendum ("92900-A").  Additionally, Correspondents are required to SUBMIT BOTH the initial and final 92900-A (with the appropriate signatures) upon submitting your Loan packages for purchase consideration.  To aid in the proper completion of the 92900-A, Citi has published a Best Practice Guide.

Envoy Mortgage CLD announced the removal of several overlays on the non-credit qualifying FHA streamline refinance products as well as a reduction to the LLPA on all FHA streamline refinance transactions effective immediately. For more information, review bulletin 15-04 on its website.

For those following interest rates, just when we think they're going up they go down, and vice versa. Despite some very positive economic data Tuesday, Treasuries ended "in the green" with longer maturities gaining the most ground - and dat's good for agency MBS prices. February New Home Sales beat estimates at 539k.

"Regular" news like that from the U.S. is consistently being trumped by overseas events impacting the world economy. The tone of the negotiations between Greece and the troika improved, sending Greece's 10-yr yield down 67 bps to 10.65%. Jeroen Dijsselbloem (run that through your spell checker!), head of the Eurogroup, said that progress is being made, and supposedly Greece will submit a reform package to the Eurogroup by Monday. Most important of all, European business activity reached a 46-month high.

For news today we've had the MBA's applications numbers. To the surprise of no one on any lock desk they rose 9.5 percent in the week ended March 20. Refis were +12% and purchases were up 5%. The refinance share of total mortgage activity increased to 61 percent of applications from 59 percent the week before.

Jobs and Announcements

Midwest Equity Mortgage, LLC is once again growing and is seeking an experienced DE/SAR Underwriter. With Midwestern principles and a conservative yet formidable growth strategy, Midwest Equity is poised to offer current and new employees outstanding opportunity. This position can work remotely from anywhere in the US. Please submit a confidential cover letter and resume to COO Eric Meadow.