RMBS Collateral: Home Equity Loans, Exotic Adjustable Rate Mortgages, and NonTraditional
Mortgages
In May 2005, NCUA issued guidance to its Federally Insured Credit Unions regarding
managing credit risk in home equity lending. NCUA indicated that (1) home equity
loans were typically long-term with interest-only features that did not require
amortization of principal for a protracted period; (2) home equity lines of credit
(HELOCs) were inherently vulnerable to rising interest rates; and (3) with the rise in
home values and demand for home equity lending, many financial institutions relaxed
underwriting standards associated with these loans, such as higher loan-to-value and
debt-to-income ratios.
In October 2005, NCUA also issued guidance to its Federally Insured Credit Unions
regarding generally increasing risks in mortgage lending. NCUA indicated there was (1)
a demand for more exotic adjustable rate mortgages, which may increase credit risk in
an environment of increasing interest rates and flattening or declining home
appreciation; and (2) a trend toward liberalized underwriting standards, which increases
credit risk. NCUA highlighted that (a) lenient credit and underwriting standards
combined with higher LTVs, interest only, or negative amortization loans and rapid
home value appreciation, could result in increased default rates; and (b) higher LTVs
combined with lower credit scores results in increased defaults.
In October 2006, NCUA issued additional guidance to its Federally Insured Credit
Unions in regards to: (1) managing risks associated with open-end HELOCs that
contain interest-only features; and (2) addressing risks associated with the growing use
of non-traditional mortgage products—including interest-only and payment option
adjustable-rate mortgages--that allow borrowers to defer payment of principal and,
sometimes, interest