Moody’s: Appraisal alternatives pose new credit risks
Could weaken credit quality of new RMBS
February 20, 2018
This is actually good news and has been consistent with what I've said before.
The "good news" is that the risk of the alternatives are being evaluated. Although the rating agencies' past* has been a bit checkered, so has everyone else associated with the mortgage meltdown (rightfully or wrongfully).
If these products are deemed more risky, then that risk will (or should) be baked into the terms/conditions of the loan.
You want a PIW or alternative? You only qualify under these conditions and within those conditions, your LTV is limited to X and/or your interest rate will be Y basis points higher.
Investors can decide if they want to purchase the riskier tranche or not; obviously, the riskier the tranche, the higher return they will demand (ergo, a higher interest rate to the consumer). Higher interest is one way to mitigate risk; another is to reduce the loan amount (and, there are more ways than those two).
The higher cost to the borrower if these types of transactions are riskier would, presumably, create a ceiling on how many of these types of transactions occur.
The danger is not in the type of valuation technique/process. The danger is, not identifying and pricing the risk of the transaction if the valuation technique creates a greater risk.
But let us face reality here: If the loan is such that the LTV is sub 50%, collateral risk may be so low that it doesn't matter.
Therefore, and again as I've said, the fight (the winnable and, from my perspective, legitimate) against these types of alternatives is not within the appraiser regulation (USPAP) arena, it is within the banking regulation (including securitization) arena.
* Some may have forgotten... when the rating agencies were hauled before lawmakers and were being sued, one of their defenses was that their ratings are simply "opinions" (just like appraisers). Part of the flack they caught was that some said for certain public transactions, they were required by regulation to rate the instrument (just like appraisers are required to perform appraisals for certain covered transactions) so because they were required, they should be held to a higher standard. However, a debt instrument doesn't need to be rated; it only needs to be rated to qualify for purchase by a certain investor-profile. Unrated securities typically pay a higher rate of return.
The similarities between the rating agencies and appraisers, and the type of instruments they rate and the type of valuation techniques we use, are pretty strong in some ways.