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Why non-QM underwriting is guiding mortgage lending's future
This has been a year of contradictions for mortgage lending. Rates remain elevated, inventory is scarce, origination volumes are weak — yet one segment of the market continues to surge. Non-QM isn't simply performing well in a difficult environment; it has become the unexpected center of gravity for the entire industry.At MBA Annual and ABS East, which ran in parallel this year, this shift was impossible to miss. Non-QM dominated panels, investor conversations, and hallway chatter. The data confirms the sentiment: Nomura's Global Markets Research reports that non-QM issuance is on track to reach $70 billion in 2025, up from $44 billion in 2024 — a remarkable 59% increase in the middle of a mortgage slowdown. When any market segment grows this quickly, skeptics ask the same thing: "Is this from loosening credit?" Nomura's answer is unequivocal — no. Non-QM underwriting standards remain tight, and the average FICO score for recent non-QM originations is among the highest ever recorded. This is not a repeat of the pre-2008 subprime era. The growth is not driven by higher risk; it's driven by better risk intelligence and risk management.Non-QM rebuilt the part of the process where the industry has always struggled: the first mile. Instead of waiting weeks to gain clarity on income, documents, and borrower fit, non-QM embraced what I call "Upfront Certainty" — moving the hardest parts of underwriting to the very first borrower interaction. Traditional mortgage workflows still depend on late-stage verification, multiple rounds of rework, and mid-process surprises. Non-QM flipped that model. Lenders now reach confidence faster, with fewer touches and far less operational drag.This transformation wasn't purely philosophical; it was technical. Non-QM was early to adopt systems that don't just extract data, but interpret it — systems that identify inconsistencies, determine what's missing, and surface risk factors before a file reaches an underwriter's desk. AI takes on the data-intensive work, while underwriters apply judgment to the nuanced cases that require human expertise. The result is not a replacement of underwriters, but a replacement of guesswork.Brokers accelerated this evolution. Once intelligence was embedded directly into TPO portals, submission quality rose almost overnight. Resubmissions declined. Pull-through improved. Borrowers received decisions faster. When brokers see a lender consistently deliver speed and clarity, the business naturally follows. Good underwriting makes good brokers better — and brokers reward the lenders who enable that.The economic impact is even more compelling. Lenders leveraging advanced non-QM workflows are scaling without proportional increases in headcount. They are entering borrower segments that once seemed too operationally heavy. They are defending — and in some cases expanding — margins in a market where margins are under immense pressure. In down cycles, operational leverage becomes a competitive advantage. Non-QM lenders have it. Traditional lenders, in many cases, don't.What is often misunderstood is that these changes won't remain isolated to the non-QM ecosystem. Everything non-QM has perfected — early-stage certainty, AI-driven verification, human-supervised decisioning, predictable workflows — will inevitably become standard across agency lending as well. The signals are already clear: stronger GSE engagement with tech partners, increased focus on early-stage income precision, and a shift toward audit-ready files from day one.Borrower expectations have changed just as dramatically. They now expect the speed of a fintech with the certainty of a bank. They will not return to a world where a mortgage requires 45 days and 20 touches to complete. The first mile has already shifted, and once that shift happens, the industry rarely goes back.Nomura describes non-QM's growth as "increasing market penetration," but the story is bigger than that. Non-QM has redefined how underwriting is done. It has created a blueprint for modern lending — one built on intelligence, precision, and early certainty. And whether lenders realize it yet or not, this blueprint is coming for every part of mortgage.This niche blueprint of today will be the industry standard tomorrow.
Fed's Cook sees risk in gen AI-manipulated financial trading
Key Insight: Federal Reserve Gov. Lisa Cook says emerging risks are arising over how artificial intelligence may influence financial markets.Expert quote: "Recent theoretical studies find that some AI-driven trading algorithms can indeed learn to collude without explicit coordination or intent, potentially impairing competition and market efficiency." — Federal Reserve Gov. Lisa Cook. What's at stake: Public officials have spoken at length in recent months about the promises or perils of AI for the economy, but Cook's remarks are among the few to consider AI impacts on market function.Federal Reserve Gov. Lisa Cook warned Thursday that generative artificial intelligence tools have the potential to shape market dynamics.Speaking at Georgetown University's McDonough School of Business, Cook, who chairs the Fed board's Committee on Financial Stability, said AI trading systems could create market disarray through collusion or manipulation, though she noted research shows the likelihood is small."Recent theoretical studies find that some AI-driven trading algorithms can indeed learn to collude without explicit coordination or intent, potentially impairing competition and market efficiency," Cook said.Cook said AI trading systems can steer market behavior, citing a recent study that found self-learning algorithms are capable of discovering spoofing strategies. She said the systems were placing large orders they never intended to execute to create false impressions of market demand.The Fed governor said that in the future AI systems could come to the market that "operate with greater opacity, execute more complex trades, and better hide manipulative intent."Cook added that the unexplainability of some complex algorithms could make it difficult to regulate or audit these tools."There are growing concerns that results obtained from complex AI models may be difficult to explain or rationalize by human experts — the 'black box' problem," she said. "The inability to fully audit trades executed by algorithms makes surveillance by trading venues and regulators more challenging."Nonetheless, Cook said that alongside tools that can be used with malicious intent, new technologies are emerging that can detect manipulative and collusive behavior."Thanks to improving surveillance capabilities, AI technology could ultimately strengthen market integrity and enhance market liquidity," Cook said. "Trading venues are also taking steps to mitigate the risk stemming from the 'black box' problem associated with AI-enabled trading algorithms."Other Fed governors, including Michael Barr and Christopher Waller, have also recently commented on how AI will impact the economy, particularly the labor market.Barr said in a speech in early November that if AI tools could make certain roles obsolete, adding that a small degree of those changes may already be occurring.However, Barr, the former Fed vice chair for supervision, emphasized that he remains optimistic about how AI will affect communities, saying he believes it will ultimately help the economy grow."I think even if there are some short-term dislocations, what we've seen with the introduction of technologies in the past is that over the long term, new jobs are created and jobs that exist change to be more productive for the worker," Barr said. "Workers get paid more, so it could increase real wages for people."Waller has similarly argued that the long-term economic benefits far outweigh the short-term labor market disruptions the technology will bring.Cook's speech Thursday comes shortly after the Fed released its semiannual Financial Stability Report, which highlighted that excessive market optimism could pose risks to financial stability if economic conditions change. Cook highlighted that overall the U.S. system is "sound and resilient."
FHA waives disclosure as nominee for commissioner advances
The Federal Housing Administration is waiving its policy requiring mortgagees to provide borrowers with a longstanding notice that lays out FHA loan rights and responsibilities.The waiver for use of the "Important notice to homebuyers" disclosure is in line with the federal government's broader deregulatory agenda, and ends the use of "a redundant and outdated form," according to an FHA information bulletin."The change could lead to faster processing times and a less cumbersome experience for the borrower," the FHA wrote.Mortgage companies have been responsible for distributing the form at the start of the loan process, obtaining the borrower's signature and maintaining it in the case binder. Topics covered in the disclosure include fraud, credit scores, prepayment and safety standards.The waiver applies only to loans the FHA has not yet endorsed and other regulatory and statutory disclosure requirements still stand.The FHA has not had a confirmed commissioner since Julia Gordon left at the end of the Biden administration, but the Senate could vote soon on nominee Frank Cassidy, who has been filling the role on an acting basis.Cassidy currently serves as principal deputy assistant secretary at the Department of Housing and Urban Development and the Mortgage Bankers Association this week pushed for both his confirmation and that of Joe Gormley, the nominee for Ginnie Mae president.FHA insures mortgages at the loan level. Ginnie guarantees securitizations of FHA loans and others that various government agencies back. Like Cassidy, Gormley currently is serving in the role he has been nominated for on an acting basis.Collectively the two agencies are responsible for a large portion of the U.S. mortgage market that the government directly backs, and the MBA President Bob Broeksmit has stressed the importance of officially putting two leaders with industry experience in charge of them."Frank Cassidy's deep expertise in real estate finance and commitment to improving housing affordability make him exceptionally qualified to lead FHA. Joe Gormley's leadership and extensive experience in housing policy and mortgage capital markets will be invaluable," Broeksmit said in a press statement,The Senate Committee on Banking, Housing and Urban Affairs voted 14-10 to advance Cassidy and Gormley by 13-11. The votes were largely along partisan lines.In confirmation hearings, Cassidy faced some concern from Democrats about the downsides of some recent efficiency measures, such as how shrinking FHA timelines for distressed home sales affected chances for families to bid on them and compete with private investors in Atlanta.He also faced questions about HUD cuts during the government shutdown, the impact on efficiency measures on housing counseling and whether he would consider making community land trusts eligible for FHA financing.Gormley has faced questions from Democrats about a reported removal of pending information related to an initiative that would create a securitization vehicle for buyout loans from reverse mortgage securitizations.A request for information HUD published earlier this year on reverse mortgages FHA insures and the related securitizations Ginnie guarantees will result in a more thoughtful approach to those markets, Gormley said in response.
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