review of ginnie mae jumbo collateral

8/19/2019 Review of Ginnie Mae Jumbo Collateral

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This commentary has been prepared by Markets Quantitative Analysis ("MQA"), which is part of Citigroup GlobalMarkets' sales and trading operations.

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Review of Ginnie Mae Jumbo Collateral

Mikhail Teytel

212 816 8465

[email protected]

Sandra Vedadi

212 816 0949

[email protected]

David Cohen

212 816 0503

[email protected]

Ginnie Mae jumbo or “M JM” issuance has risen at the end of

2010, reaching $600M per month.

Prepayments

of

Ginnie

Mae jumbo

pools

are

much

faster

than

prepayments of the conforming Ginnies, and over the past two

years frequently stayed in the 50%‐70% CPR range. Refinancings

are the greatest cause of fast speeds, although defaults may

contribute as well.

Although jumbo Ginnie borrowers are typically more affluent than

conforming Ginnie borrowers, Ginnie jumbo default experience is

comparable to that of conforming Ginnies. Variations in credit

between Ginnie jumbo pools are frequently more important for

defaults than higher loan size.

A

reduction

in

the

FHA

conforming

limit

may

lower

Ginnie

jumbo

speeds by 20%‐30%. This together with the recently announced

increase in the annual MIP may significantly improve Ginnie Mae

jumbo convexity.

After the burst of the housing bubble in 2008, the supply of credit to private label jumbo loans dried up.

To address this problem, the government increased FHA loan limits. In order to securitize high‐balance

FHA loans, Ginnie Mae expanded the Ginnie Mae II program to introduce a new non‐TBA‐eligible pool

type “M JM” ‐ the focus of this article. Throughout this article, we will refer to the Ginnie II “M JM”

collateral as Ginnie Mae jumbos, and will review legislation governing their issuance as well as their

production volumes, collateral characteristics, and delinquency and prepayment patterns. We will also

compare Ginnie jumbos to conventional agency jumbos and traditional conforming Ginnie II collateral.

Finally,

we

will

discuss

the

impact

of

the

recent

Ginnie

Mae

underwriting

changes

and

of

a

possible

reduction in the FHA loan limit on Ginnie jumbo speeds. For our analysis, we will consider 30‐year

collateral, which constitutes the bulk of the issuance.

Legislation Governing FHA Jumbo Production

Composition of “M JM” Ginnie pools is affected by the loan limits of FHA, VA, and other government

loan guaranty programs, as well as Ginnie Mae TBA eligibility rules. The TBA eligibility rules are

important because jumbo collateral generally trades at a discount to TBAs and originators would,

whenever permitted, place cheaper jumbo loans into higher priced TBA–eligible pools. Only jumbo loans

that could not, for one reason or another, be placed into TBA‐eligible pools would end up in MJM pools.

Changes

in

FHA

loan

limit

Traditionally, the FHA loan limit has been set at about 87% of the conforming limit. However, a series of

enactments changed this rule (see Figure 1). The starting point was the Economic Stimulus Act of 2008

(ESA) which temporarily increased the FHA loan limit depending on the Metropolitan Statistical Area

(MSA). Subsequently, the Housing and Economic Recovery Act of 2008 (HERA) established permanent

MSA‐specific loan limits which were lower than the ESA limits. However, in the beginning of 2009, these

limits were restored to their ESA 2008 levels by the American Recovery and Reinvestment Act (ARRA).

February 24, 2011 Market Quantitative Analysis


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Review of Ginnie Mae Jumbo Collateral February 24, 2011

This commentary has been prepared by Markets Quantitative Analysis ("MQA"),

which is part of Citigroup Global Markets' sales and trading operations.

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Figure 1. Impact of Enactments on FHA loan limits si nce 2008

Economic Stimulus Act (ESA) of2008

Housing and Economic Recovery Act (HERA) o f 2008

Amer ican Recovery andReinvestment Act (ARRA) of2009

EnactmentDate

February 13, 2008 July 30, 2008 February 17, 2009

FHAmaximumloan size

125% of the median house price inthe geographic area, but floored at$271,050 and capped at $729,7501

115% of the median house price inthat geographic area, but floored at$271,050 and capped at $625,500

ESA limits

FHA LoanOriginationDate

On or Before December 31, 2008 butloan endorsed after March 6,2008

On or After January 1, 2009January 1, 2009 throughDecember 31, 2009 (laterextended to September 30, 2011)

Source: HUD (Morgage Letter 08-06, 08-36, 09-07, 09-50, 10-40) and Citi.

Changes in VA guaranty

Unlike the FHA, the VA does not guarantee the entire principal of the loan. Instead, the VA guarantees

only a fraction of the loan up to a maximum amount called the VA entitlement. Traditionally, the

entitlement was county‐specific, but generally limited to 25% of the conforming limit, which allowed

lenders to originate conforming VA loans with no down payment. Theoretically, there was never a limit

to the size of a VA loan. A non‐conforming loan would require a down payment that together with the

VA entitlement would constitute 25% of the home value. For example, in the first half of 2008, the

maximum guaranty offered by VA was limited to 25% of the conforming loan limit of $417K, or about

$104K. If a veteran wanted to buy a $500,000 home, a lender would typically require about $21,000 in

down payment.

The dollar amount of VA entitlements has increased in step with increases in the conforming limit.

Moreover in some high‐cost counties, the VA entitlement was raised above 25% of the conforming limit.

Changes

in

Ginnie

Mae

TBA

pooling

Requirements

Traditionally, Ginnie Mae restricted the size of loans allowed to be placed into a TBA‐eligible pool, with

the cutoff at about 87% of the conforming limit. However, in September 2007, the limit on the size of VA

loans was lifted, and VA loans of any size were allowed into TBA‐eligible pools. After the limit on FHA

loan size was raised in 2009, Ginnie Mae allowed loans exceeding a certain threshold, called the high‐

balance loan limit, to be placed into TBA‐eligible pools, albeit subject to the 10% de minimus rule. At the

same time, the VA exception was terminated, placing VA loans under the same 10% de minimus rule.

Recent changes to the Ginnie Mae TBA pooling requirements are delineated in Figure 2.

1 Higher limits apply to 2‐4 unit properties or properties located in AK, GU, HI and VI.


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Figure 2. GNMA TBA Eligibility fo r 1-Unit Property

September 1 2007 Apr il 1, 2008 January 1, 2009

Loan Origination Date Before October 1,2008 On or After October 1, 2008

High-Balance Loan Limitfor 1-Unit Properties2

$362,790 $417,000

TBA Eligibility RuleHigh Balance Loans are not allowed (see VA exception

below)

High-Balance loans may be pooled intoTBA-eligible pools subject to the 10%

de minimus rule

Exception for VA loansVA loans are allowed in TBA-eligible pools without any

loan size restriction.

High-Balance VA loans may be pooledinto TBA-eligible pools subject to the

10% de minimus ruleSource: Ginnie Mae (APM 08-05, 08-06, 08-25, 09-07) and Citi.

Issuance

Issuance of Ginnie Mae jumbo collateral is shown Figure 3. After the ESA Act of 2008, jumbo issuance

started

to

rise,

reaching

almost

$2

billion

per

month

by

the

summer

of

2008.

At

that

point,

the

share

of

jumbo issuance reached 18% of the total Ginnie II 30 year issuance. However, since the beginning of

2009, the issuance of “M JM” dropped for a variety of reasons, including the reduction of the FHA loan

limit by HERA, ability, albeit limited, to securitize jumbo loans into TBA‐eligible pools, and the

introduction of competing conventional products (agency jumbos). As seen in Figure 4, issuance of

Fannie Mae Jumbo pools (designated by the prefix CK) increased relative to issuance of Ginnie jumbos.

At the end of 2010, lower mortgage rates drove “M JM” monthly issuance to above $600 MM. The bulk

of recent jumbo issuance has been in 4s and 4.5s.

2 Higher limits apply to 2‐4 unit properties or properties located in AK, GU, HI and VI.


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Figure 3.GN II Jumbo Issuance and th e Ratio of GN II JumboIssuance to GN II Confor ming 30-Yr Issuance

Source: CPRCDR and Citi.

Figure 4. Fannie Mae and Ginni e Mae Jumbos Iss uance

Source: CPRCDR and Citi.

Collateral Characteristics

Figure 5 and Figure 6 compare collateral characteristics of jumbo and conforming Ginnie IIs. As expected

jumbo collateral pools have larger loan sizes (2.5 times bigger) than traditional Ginnie IIs (see Figure 5).

Jumbo 2008 collateral has a somewhat lower loan size than 2009 and 2010, which may be due to the

change in the loan size limit.

When compared to GN II 30 Yrs, jumbos have somewhat lower original LTVs and higher FICO scores,

suggesting somewhat better credit — perhaps the result of jumbo borrowers being more affluent. The

data shows that 2008 jumbo loans have somewhat poorer credit scores than 2009 and 2010 loans.

However, the FICO sample size is rather small for pools originated in 2008.

Figure 6 shows that jumbo pools, especially those originated in 2009 and 2010, when interest rates were

low, have a significantly larger fraction of refinance loans compared to GN II, which is a consequence of

their higher refinancing incentive.

On average, jumbo pools have a higher share of FHA loans than VA loans, which is consistent with the

composition of conforming Ginnies. However, for lower coupons, the FHA share is lower for jumbos

than for conforming Ginnies, and for higher coupons — it’s higher. Another interesting observation is

that jumbo collateral originated in 2008 has very few VA loans. Recall that in 2008, VA loans could be

placed

into

conforming

TBA

pools

without

loan

size

restrictions.


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Figure 5. Current Balance, Current L oan Size, Credit Scor e and OLTV of Ginnie Ju mbos and Ginnie II 30 year Collateral, January 2011

CBal ($MM) Cloan size (K) FICO OLTV

Coupon Year Jumbos GN II Jumbos GN II Jumbos GN II Jumbos GN II

3.5 2010 24 1,260 503 195 757 720 92 9

4.0 2009 103 2,406 494 190 689 665 90 9

4.0 2010 1,727 35,161 541 198 740 719 92 9

4.5 2009 424 48,338 483 185 664 681 94 9

4.5 2010 1,680 77,829 528 185 731 710 93 9

5.0 2008 206 3,661 428 167 673 661 93 9

5.0 2009 614 64,976 493 166 714 647 93 9

5.0 2010 774 57,186 516 162 723 690 93 9

5.5 2008 745 17,449 431 152 632 651 93 9

5.5 2009 271 7,107 480 137 694 629 91 9

5.5 2010 21 2,245 459 118 698 644 92 9

6.0 2008 332 8,258 434 130 603 635 92 9

6.0 2009 35 846 407 111 608 602 93 9

6.5 2008 191 4,475 424 114 615 612 92 9

7.0 2008 34 385 429 94 635 589 89 9

Source: Citi, CPRCDR

Figure 6. Loan Purpos e and Loan Type, January 2011

CBal ($ MM) % REFI % Purchase % FHA % VA

Coupon Year Jumbos GN II Jumbos GN II Jumbos GN II Jumbos GN II Jumbos GN II

3.5 2010 24 1,260 51.7 17.6 31.7 53.1 44.0 61.5 56.1 34

4.0 2009 103 2,406 52.4 21.0 29.6 43.5 58.0 70.7 42.0 26

4.0 2010 1,727 35,161 53.7 36.6 31.1 46.4 78.3 70.0 21.5 26

4.5 2009 424 48,338 49.9 37.0 35.3 45.2 60.5 74.5 38.6 21

4.5 2010 1,680 77,829 50.1 29.7 39.5 54.8 70.5 76.2 29.5 19

5.0

2008

206

3,661

20.0 21.6 36.0 30.5 99.5

69.7 0.5 275.0 2009 614 64,976 42.7 31.4 46.4 51.6 81.7 81.5 17.3 13

5.0 2010 774 57,186 37.7 28.8 53.3 58.1 74.6 83.6 25.2 12

5.5 2008 745 17,449 27.4 30.1 50.8 40.2 99.2 80.7 0.6 15

5.5 2009 271 7,107 45.5 28.6 43.8 56.8 91.1 85.8 8.0 11

5.5 2010 21 2,245 53.1 36.5 42.3 49.5 88.0 88.4 12.0 10

6.0 2008 332 8,258 31.7 30.5 53.3 44.6 99.9 84.6 0.2 9

6.0 2009 35 846 38.7 22.4 48.5 55.0 90.8 88.9 9.2 7

6.5 2008 191 4,475 43.9 33.6 48.2 48.1 100.0 87.6 0.0 6

7.0 2008 34 385 53.5 36.1 39.9 50.1 100.0 95.2 0.0 3Source: Citi, CPRCDR

Geographical Distribution

Figure 7 shows the geographic distribution for jumbo collateral. Since FHA and VA loan limits are not

uniform across the country, the geographic distribution of Ginnie jumbos is different from that of

conforming Ginnies. Jumbo collateral has a larger share in more expensive states, with California and

New York accounting for more than 50 % of the jumbo issuance. While differences in geographic

composition most likely have an effect on jumbo prepayments, jumbo speeds are typically faster than

those of conforming Ginnies for all states, suggesting that geography is not the most important driver of

fast jumbo speeds.


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Figure 7. Geographi cal Distribu tion o f Ginnie Mae Jumbo Coll ateral as of December 2010

% Distribution CPR 1yr for 2008 6s

State Jumbo GN II Jumbo GN II

CA 37.1% 10.2% 38.3 21.9

VA 14.0% 4.6% 25.5 16

NY 14.0% 3.4% 17.2 9.5

MD

9.4%

3.0% 29.5

21.3NJ 6.3% 2.8% 32.3 17.1

WA 3.7% 3.2% 39.6 19.5

MA 2.4% 1.5% 39.4 26.1

DC 1.6% 0.3% 18.1 19.8

CT 1.4% 1.0% 29.7 14.8

FL 1.4% 5.2% 17.6 9.6

PR 1.2% 0.0% 4.6 0

HI 1.2% 0.4% 36.8 19

CO 1.0% 3.4% 46.4 18.6

US 100.0% 100.0% 32.9 15.8Source: Citi, CPRCDR

Servicers

The servicer distribution for jumbos changed somewhat between 2008 and 2009 (see Figure 8). In 2008

there was a large concentration in two servicers: Chase and Wells Fargo (about 45%), but in 2009 and

2010 the share of these two servicers declined as they shifted some of their jumbo production to

conventionals and TBA‐eligible Ginnies.

Figure 8. Servicer Dist ribut ion of Ginnie Mae and Fannie Mae Jumbo Collateral (Fannie as of January 2011, Ginnie as of December2010)

% per Servicer in 2008 % per Servicer in 2009 % per Servicer in 2010

GN

Jumbo

GN II

30

FN

Jumbo

GN

Jumbo

GN II

30

FN

Jumbo

GN

Jumbo

GN II

30

FN

Jumb

CHASE

24.2

15.6

12.5

BOA‐CW 16.9 31.3 17.0 UNRPT

20.9 13.5 5.1

BOA‐CW 21.3 24.6 17.1 CITI 13.1 2.5 4.9 BOA‐CW 19.8 23.7 19.6

WFHM 20.7 19.0 21.9 NAVY 13.1 0.2 ‐ CHASE 10.9 7.8 10.7

CITI 10.0 6.5 12.6 CHASE 6.6 9.0 11.5 WFHM 6.7 30.1 30.4

GMAC 3.8 4.1 2.7 PHH 5.9 2.4 1.4 GMAC 6.5 3.9 6.0

TBW 2.7 5.9 ‐ GMAC 5.7 5.9 4.3 NAVY 6.1 0.0 0.2

FLAG 2.3 3.9 0.8 FLAG 5.4 2.0 0.5 METLIFE 5.7 1.2 2.0

METLIFE 1.7 0.5 2.9 METLIFE 5.3 2.6 10.6 CITI 4.2 1.3 6.0

SUN 1.6 2.6 3.3 WFHM 4.7 25.8 32.6 PHH 3.1 3.1 2.3

PHH 1.3 2.0 0.8 FRDOM 3.2 0.6 ‐ FLAG 2.8 1.1 1.2

BBT 1.2 1.6 ‐ BBT 2.5 0.9 2.4 FRDOM 1.9 0.6 ‐

USB 1.1 1.7 ‐ MTB 2.2 0.1 ‐ SUN 1.6 1.1 1.4

FT

1.0

0.4 ‐

HSB 1.2 ‐ ‐

MTB

0.7 0.0 ‐

PNC 0.9 2.7 0.2 DORAL 1.0 ‐ ‐ QUICK 0.6 0.0 0.7

MTB 0.7 0.0 ‐ HSBC 0.7 0.0 3.4 HSBC 0.6 ‐ 1.1

HSBC 0.5 0.2 0.9 PNC 0.7 1.5 0.0 BBT 0.5 0.9 0.0



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Delinquencies

Figure 9 compares jumbo and conforming Ginnie 60‐day delinquencies for 6s of 2008 and 5s of 2009.3 6s

of 2008 had lower delinquencies than conforming Ginnies until the middle of 2009, after which the

trend reversed. For 5s of 2009, jumbo and conventional delinquencies were similar, perhaps with

somewhat lower level for jumbos. A similar pattern is observed for other cohorts: for 2008 production,

jumbo defaults

are

higher

than

conforming

Ginnies,

and

for

2009

and

2010

collateral,

default

rates

are

similar, at least so far.

Figure 9. 60-Day Delinquency for 2008 6s (left) and 2009 5s (righ t)


Ginnie Mae servicers have an option to repurchase 90‐day delinquent loans at par out of GNMA pools,

and buyouts can contribute significantly to overall speeds. Figure 10 compares buyouts, measured in

constant buyout rate (CBR%), for jumbo and conforming Ginnie collateral. For 6s of 2008, jumbo

buyouts are considerably faster because of higher delinquencies. Are jumbo Ginnies bought out more

efficiently by servicers than conforming Ginnies? Figure 11 shows ratios of buyouts to 90‐day

delinquencies. While

buyout

efficiency

is

similar

for

2008

cohorts,

it

is

lower

for

2009

collateral.

Figure 10. 1-Month CBR for 2008 6s (left) and 2009 5s (right )

0

5

10

15

20

25

30

35

40

45

50

Apr-08 Aug-08 Dec-08 Apr-09 Aug-09 Dec-09 Apr-10 Aug-10 Dec-10

1 -

M o n t h C B R ( % )

GN II 30 Yr

Jumbo

0

1

2

3

4

5

6

7

8

9

10

Feb-09 Jun-09 Oct-09 Feb-10 Jun-10 Oct-10

1 - M o n t h C B R ( % )

GN II 30 Y r

Jumbo


3 We have chosen the 60‐day delinquencies because they are indicative of collateral performance, while 90‐day

delinquencies are affected by servicer buyouts.


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Figure 11. Ratio of 1-Month CBR to % 90D for 2008 6s (left) and 2009 5s(right )


Overall

we

believe

that

Ginnie

jumbo

default

experience

is

generally

in

line

with

that

of

conforming

Ginnies. All else being equal, higher loan size most likely leads to higher defaults. However, all else is

rarely equal. The credit quality of jumbo pools, including FICO and current LTV, vary from vintage to

vintage and frequently from pool to pool, and variations in credit quality are generally more important

determinants of defaults than loan size. Each pool should be analyzed on its own merits.

Prepayments

Over the past two years, Ginnie jumbo prepayments were very fast, frequently in the 50%‐70% CPR

range (see Figure 12).

Figure 12. 1-Month CPR for 2008 6s (left) and 2009 5s (right)


Fast in the money speeds for jumbos are expected and are likely to continue in the future. Ginnie Maes

are no exception. Fast jumbo speeds are caused by very large dollar incentives – a direct consequence of

high loan size. For Ginnie loans, which have a popular streamlined refinancing program, refinancing an in

the money jumbo loan may be very attractive. Many Ginnie borrowers choose a no‐point no‐cost

refinancing, where all refinancing costs are converted into a higher mortgage rate. When a jumbo Ginnie

borrower is sufficiently in the money to lower their rate through a no‐point no‐cost refi, prepayments


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should be fast, and they were. Recent tightening of the FHA’s streamlined refinancing rules may have

moderated speeds slightly (see the January 2010 drop in speeds of 6s of 2008 in Figure 12), but speeds

remained very fast.

Comparison to Conventional Jumbos

In Figure

13,

we

compare

the

prepayment

S

‐curves

of

conventional

agency

jumbos,

Ginnie

Mae

jumbos

and conforming Ginnie IIs. The S‐curves for conventional and Ginnie Mae jumbos are steeper than for

conforming Ginnies – a consequence of jumbo’s higher sensitivity to mortgage rates. Amongst the

jumbos, the conventional S‐curve is steeper than the one for Ginnies – most likely resulting from higher

loan sizes and better credit for conventional jumbo borrowers.

Figure 13. Convention al Agency Jumb o, Ginnie Mae Jumbo and Con formin g Ginnie II Prepayment S-Curves for 2008 and 2009 Origination, Apr2008 to January 2011

2008 Origination Year

0

10

20

30

40

50

60

70

-100 0 100 200 Incentive (bp)

1 m o n t h C P R ( %

GN Jumbo

GN II

FN Jumbo

2009 Origination Year

0

10

20

30

40

50

60

70

-100 0 100 200 Incentive(bp)

1 m o n t h C P R ( %

GN Jumbo

GN II

FN Jumbo

Source: CPRCDR

In Figure

14,

we

take

a

look

at

the

collateral

characteristics

of

Ginnie

Mae

and

Fannie

Mae

jumbos

as

of

January 2011. The loan size is higher for conventional jumbos by $50K‐$100K. Conventional jumbos also

have better credit than Ginnie jumbos: current LTVs are 20%‐30% lower and FICOs are often 50‐100

points higher.


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Figure 14 Current Balance, Current Loan Size, Credit Score* and OLTV of Ginnie Jumbos and Fannie Jumbo s Collateral

CBal ($ MM) Cloan size (k) CLTV FICO 1 Month CPR (%)

Coupon YearGN

JumboFN

JumboGN

JumboFN

JumboGN

JumboFN

JumboGN

JumboFN

JumboGN

JumboFN

Jumbo

3.5 2010 24 255 503 577 92 67 757 775 0 4.2

4 2009 103 384 494 527 91 60 689 772 0.1 13.5

4 2010 1,727

12,798

541

581

92

66

740

772

1.5

5.7

4.5 2009 424 6,384 483 551 94 64 664 767 14.7 30.4

4.5 2010 1,680 13,918 528 578 92 66 731 768 4.5 22.1

5 2008 206 449 428 578 101 73 673 761 36.8 61.7

5 2009 658 4,296 492 549 93 70 714 761 27.4 38.5

5 2010 774 4,311 516 571 91 70 723 759 24.2 35.7

5.5 2008 837 1,142 431 550 101 77 636 757 39.1 58.2

5.5 2009 271 241 480 545 93 73 694 747 32.4 34.8

5.5 2010 21 58 459 564 91 77 698 741 61.7 9

6 2008 1,011 935 424 549 98 81 611 750 47.5 54.4

6 2009 38 38 400 549 96 77 608 721 20.5 45.9

6.5 2008 305

190

422

553

97

82

619

737

46.6

47.1 6.5 2009 17 2 461 637 94 81 751 49.4 0

7 2008 34 16 429 555 93 83 635 712 26.2 61 Source: CPRCDR and Citi.

Recent Underwriting Changes May Improve Ginnie Jumbo Convexity

Recent changes to the Ginnie Mae underwriting guidelines will likely impact all Ginnie Mae collateral,

including Ginnie Mae jumbos. In particular, a 25bp increase in the annual insurance premium, will

reduce refinancing incentive by 25bp, which according to Figure 13, may result in slower speeds by

about 5%‐10% CPR.

A possible reduction in the Ginnie Mae conforming limit may further damped jumbo speeds. In a recent

white paper,4

the

Treasury

alludes

that

the

increase

in

the

conforming

limit

due

to

ARRA

may

expire

in

September 2011. Ginnie Mae jumbo borrowers, whose average LTV is above 90%, will typically not be

able to refinance into non‐agency loans, and therefore borrowers with a loan size above the new

conforming limit may not be able to refinance at all.

We estimate that if conforming limits revert to the HERA’s level, jumbo voluntary speeds may decline by

20%‐30%, although a larger drop is possible. The uncertainty in our estimate is due to the fact that the

FHA conforming limits are determined on the MSA level and the exact percentage of loans that would

become non‐conforming is hard to estimate. Figure 15 shows that roughly 20% of Ginnie Mae jumbo

loans will exceed the maximum conforming limit under HERA ($625K). We estimate that perhaps

another 10% of jumbo collateral, while under the maximum conforming limit, will exceed the

conforming limit for their MSA, and therefore will not qualify for another FHA loan.

This analysis suggests that the reduction in the conforming limit may reduce peak in‐the‐money jumbo

speeds from about 60% CPR to about 45%. This would lead to a considerable improvement in the

convexity of jumbo loans. However, since the details of the transition have not been released, risks

remain. For example, it is possible that after ARRA expires, legacy jumbo loans could still be considered

conforming.

4 “Reforming America’s Housing Finance Market. A Report to Congress”, February 2011


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11

Figure 15 Average loan s ize quar ti les for Ginn ie Mae J umbo Pools , $ in Thousand.

Min Q2 Q3 Q4 Max

181 457 517 608 874Source: CPRCDR and Citi.


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