Mortgage Banking Accounting - Part 3

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Mortgage BankingAccounting – Part 3Federal Home Loan Bank Des MoinesEric Nokken, DirectorAnneliese Ramin, Senior ManagerWilary Winn LLCAugust 23, 2022

MORTGAGE BANKING WEBINARS1) Mortgage Lending Part I – Sell or Hold2) Mortgage Lending Part II – Best Execution3) Mortgage Banking Accounting2

TOPICS FOR TODAY’S SESSIONS1)Valuation and accounting for Mortgage Pipeline Hedging1) Interest Rate Lock Commitments2) Forward Mortgage Loan Sales Commitments3) Closed Loans Held for Sale2)Valuation and accounting for Retained Mortgage Servicing Rights1) Credit Enhancement Fee Receivable & Obligation Liability3)Regulatory Capital & Reporting Requirements1) MPF program3

TODAY’S PRESENTERSEric NokkenMr. Nokken has over twenty years of experience in the financial services industryand has been with Wilary Winn since 2004.Mr. Nokken leads Wilary Winn’s mortgage banking activities line of business. Eric’steam provides mortgage servicing rights valuations on portfolios that range in sizefrom 4 million to over 4 billion for more than 375 clients across the country. Eric isan expert in the accounting and regulatory reporting related to mortgage bankingactivities, including interest rate lock commitment and forward loan salecommitment derivatives, as well as mortgage servicing rights.Mr. Nokken also values commercial servicing rights, SBA servicing rights and gainon sale calculations related to SBA loan sales as well as auto, home equity andHELOC servicing related to loan sale participations.Contact Information: 651-224-1200 or -nokken/4

TODAY’S PRESENTERSAnneliese RaminIn her role as a senior manager, Ms. Ramin leads analysts performing valuationsof residential mortgage servicing rights portfolios, commercial servicing rights,Small Business Association (SBA) servicing rights, gain on sale calculationsrelated to SBA loan sales, and trust preferred collateralized debt obligations. Shealso works to build these business lines, ensure the work is properly staffed, andmentor our team of financial analysts.Anneliese joined Wilary Winn in 2015. She has a bachelor’s degree in actuarialscience from the University of Wisconsin-Eau Claire.Contact Information: 651-224-1200 or se-ramin/5

MORTGAGEPIPELINE HEDGING

Mortgage Pipeline HedgingGuidance Interagency advisory on mortgage banking – February 2003 Interagency advisory on accounting and reporting for commitments tooriginate and sell mortgage loans – May 2005 OCC Comptroller’s Handbook Mortgage Banking – February 20147

Mortgage Pipeline HedgingInteragency Advisory on Accounting and Reporting forCommitments to Originate and Sell Mortgage LoansProvides guidance on accounting and reporting for commitments to: Originate mortgage loans that will be held for resale; and Sell mortgage loans under mandatory and best-efforts sales contracts8

Mortgage Pipeline HedgingInterest Rate Lock Commitments (“IRLCs”) Interest rate lock in commitments on mortgage loans that will be held for resaleare derivatives Commitments to originate mortgage loans to be held for investment and othertypes of loans are generally not derivatives9

Mortgage Pipeline HedgingTypes of IRLCs Lock ins for fixed rate loans Lock ins for adjustable-rate loans Commitments with floating rates10

Mortgage Pipeline HedgingIRLC Valuation Components Loan amount Interest rate Price of the loan at valuation date Value of servicing Discount points Direct origination fees and costs11

Mortgage Pipeline HedgingIRLC Valuation Example12Loan Amount 250,000Price to the borrower at lock-in:Par or 100Locked Interest Rate5.250%Market Interest Rate4.875%Sales Price (locked with investor)101.50Value of Servicing0.909% or 2,273Projected Origination Costs1.000% or 2,500

Mortgage Pipeline HedgingIRLC Valuation ExampleLoan Amount(A)InceptionRatesIncrease50 bpLoanHas BeenProcessedRatesDrop100 bpLoanHas BeenApprovedLoanatClose 250,000 250,000 250,000 250,000 250,000 250,000Lock In Interest Rate5.250%5.250%5.250%5.250%5.250%5.250%Market Interest Rate4.875%5.375%5.375%4.375%4.375%4.375%Market Value(B)101.500%99.500%Servicing ation er Price(E)Value as a Percent of Loan(B) (C) - (D) - (E)(F)Dollar Value (A) * (F)(G)Pull-through Percentage(H)Net Value (G) * (H)(I)Value Recorded1399.500% 103.500% 103.500% 103.500%100.000% 100.000% 100.000% 100.000% 100.000% 100.000% 1.409%-0.591%3,523 (1,477) 30.00%30.00% 1,057 (443) 1,057 (1,500) -0.091%3.909%(227) 60.00% 10,39860.00%(136) 3079,7734.159% 4.409% 11,02380.00%100.00%5,864 8,319 11,0236,000 2,455 2,705

Mortgage Pipeline HedgingOther Valuation Considerations Changes in interest rates can also affect the value of the servicing asset Pull-through assumptions in the marketplace are more complex than thesimplified example14

Mortgage Pipeline HedgingFactors Affecting Pull-through and the Hedge Market interest rates Type of origination – retail or wholesale Length of lock Purpose of loan – purchase or refinance Type of loan – fixed or variable Processing status of loan15

Mortgage Pipeline HedgingTypes of Sales Commitments Mandatory delivery Best efforts delivery Master agreements16

Polling Question #1

Mortgage Pipeline HedgingMandatory Delivery CommitmentAn institution commits to deliver a certain amount of loans to aninvestor at a specified price on or before a specified dateRequires a pair-off fee based on then current market prices tocompensate investor for any shortfallExamples: FHLB/FNMA/FHLMC cash window MBS TBAs MBS Assignment of Trade (AOTs)18

Mortgage Pipeline HedgingCash Versus MBS Pricing ComponentsCash Price Components Commitment price Interest rate Type of loan Loan term Loan level price adjustors ServicingMBS Pricing Components Market price Guarantee fee Buyups and buydowns Pooling considerations19

Mortgage Pipeline HedgingMandatory Delivery Contracts are Derivatives Has a “specified underlying” – the specified price Requires little or no initial net investment Has a “notional amount” – the principal amount of the loan Requires or permits net settlement by paying a pair-off feebased on then current market prices Is a derivative20

Mortgage Pipeline HedgingBest Efforts Delivery Commitments An institution commits to deliver an individual loan of a specifiedprincipal amount and quality to an investor if the loan to theunderlying borrower closes Generally not considered a derivative until the loan closes becauseit does not meet the net settlement criteria The result is that the change in the value of best-efforts contractswill not offset the change in the value of the IRLCs for accountingpurposes unless fair value is elected An institution will want to elect fair value if they want a “hedge”against the fluctuation in the value of the IRLC21

Mortgage Pipeline HedgingValue of Forward Loan Sale CommitmentLoan Amount(A)InceptionRatesIncrease50 bpLoanHas BeenProcessedRatesDrop100 bpLoanHas BeenApprovedLoanatClose 250,000 250,000 250,000 250,000 250,000 250,000Lock In Interest Rate5.250%5.250%5.250%5.250%5.250%5.250%Market Interest Rate4.875%5.375%5.375%4.375%4.375%4.375%Market Value(B)101.500%99.500%Servicing Value(C)0.909%0.909%Sales Price including SRP(D)Value as a Percent of Loan(D) - (B) - (C)(E)Dollar Value (A) * (E)(F)Pull-through Percentage(G)Net Value (F) * (G)(H)Value Recorded2299.500% 103.500% 103.500% 103.500%0.909%0.909%0.909%0.909%102.409% 102.409% 102.409% 102.409% 102.409% 102.409%0.000% -2.000% 30.00%5,0002.000% 30.00%5,00060.00%-2.000%-2.000%-2.000% (5,000) (5,000) (5,000)60.00%80.00%100.00% - 1,500 3,000 (3,000) (4,000) (5,000) - 1,500 1,500 (6,000) (1,000) (1,000)

Mortgage Pipeline HedgingNetting of Derivatives for Reporting Purposes May net gains and losses of individual derivative commitments onlyunder certain conditions, generally only under the legal right ofoffset The value of sales commitments covering the pipeline may not benetted against the value of the IRLCs, they must be reportedseparately The value of sales commitments covering the warehouse may notbe netted against the value of the warehouse loans, they must bereported separately23

Mortgage Pipeline HedgingClosed Loans Held for Sale Loans Held for Sale (“LHFS”) are reported at lower of cost or marketunless fair value is elected An institution will want to elect fair value if they want a “hedge” againstthe fluctuation in the value of the mandatory commitment24

MORTGAGESERVICINGRIGHTS

MSR – Valuation ConsiderationsRetained Mortgage Servicing Rights MSRs are a modified interest only strip Many types of underlying loans Value varies significantly by type of MSR26

MSR ValuationInteragency Advisory on MSRs Requires comprehensive documentation of valuation process Valuation must be based on reasonable and supportable assumptions andmajor changes to assumptions must be approved Compare assumptions to actual results Use appropriate amortization and recognize impairment timely27

MSR – Valuation ConsiderationsValuation Inputs & Loan Performance Loan amount Servicing fee percentage – varies by investor and type of loan Costs to service – market costs Expected loan life Loan term Prepayment Delinquency rates Foreclosure losses – recourse versus non-recourse Ancillary income Float Income on P&I payments and escrow payments Discount rate28

MSR Valuation InputsInput Considerations Servicing fees are earned monthly based on remainingprincipal balance Servicing costs should be based on the market and calculatedin dollars per loan not in basis points Ancillary income includes late fees, insurance income andother fees earned Float and escrows (impounds) add value29

Polling Question #2

MSR Valuation InputsRange of Valuation InputsAncillary IncomeFNMA / FHLMCFixedARMGNMAFixedARMDiscount RateFNMA / FHLMCFixedARMGNMAFixedARMServicing CostsFNMA / ata Not .50%9.10%12.50%10.49%Data Not 49Data Not Received66.2169.2364.5367.7275.29PWC Summary asof May 31, 2022

MSR ValuationInput SensitivityValueChange% ChangeBase0.909%Prepayments increase 30%0.794%-0.115%-12.7%Servicing costs increase 30%0.874%-0.035%-3.9%Delinquencies increase 30%0.908%-0.002%-0.2%Discount rate increases 30%0.836%-0.073%-8.0%Source: Wilary Winn, July 31, 202232

LOAN SERVICINGValue of Servicing30 Year Conforming Conventional Par Rate Servicing Fee Value1.250%1.000%0.750%Value0.500%0.250%-200 bps-100 bps-50 bpsBase 50 bpsChange in Interest Rates33 100 bps 200 bps

34MSR Value %Prepayment SpeedJun. 2022Dec. 2021Jun. 2021Dec. 2020Jun. 2020Dec. 2019Jun. 2019Dec. 2018Jun. 2018Dec. 2017Jun. 2017Dec. 2016Jun. 2016Dec. 2015Jun. 2015Dec. 2014Jun. 2014Dec. 2013Jun. 2013Dec. 2012Jun. 2012Dec. 2011Jun. 2011Dec. 2010Jun. 2010Dec. 2009Jun. 2009Dec. 2008Jun. 2008LOAN SERVICINGValue of ServicingValue of MSR 0.700%3000.550%2000.400%100

MSR ValuationStochastic Modeling Supply prices to solve for option adjusted spread (“OAS”) with aMonte Carlo Simulation Works best with residential mortgage loans and securities Interest rate movement is random Multiple simulations (thousands) of interest rate movements areperformed for estimating probability distributions35

MSR ValuationRandom Paths Assuming a 4% Starting Rate and a MeanReversion MethodOAS Example36

MSR ValuationOAS Advantages Use of a probabilistic model consistent with the current termstructure of interest rates and the assumed level of volatility Development of explicit pricing and valuation for embeddedoptions, such as the prepayment option Use of simulation methodology that is more theoretically sound,approximating the methodologies used to value hedgeinstruments and mortgage securities37

MSR ValuationOAS Disadvantages Lack of precise market prices for specific MSAs. The OAS used inthe model, like the discount rate used in static analysis, is arbitrary Requirement of more resources than static analysis in terms ofcomputing power, software, and model sophistication Lack of set standards for OAS computation. OAS model resultsare highly dependent on input assumptions such as volatility,prepayment speed, default rates, inflation, the appropriate risk-freerate (Treasury or SOFR), and the setting of model parameters, allof which can result in different OAS and MSA values Lack of consistency in OAS model methodology that may result inasset valuation differences38

Credit EnhancementFees Receivable &Credit EnhancementObligation Liabilities

MORTGAGE PARTNERSHIP FINANCE PROGRAMStructure DetailMPF Xtra40MPF OriginalMPF 125

MORTGAGE PARTNERSHIP FINANCE PROGRAMMPF Program Structure Detail Provides equal access to secondary market opportunities MPF Xtra – access secondary market liquidity, minimize interestrate and prepayment risk, transfer loan credit risk to the investor. MPF Traditional – be rewarded for originating quality conventionalloans that perform over time MPF Government – sell fixed-rate mortgage loans insuredor guaranteed by government agencies including FHA, VA,RHS Sec. 502, HUD Sec. 18441

MORTGAGE PARTNERSHIP FINANCEPROGRAMCE Recourse Liability VS. CE Recourse Obligation Amount The CE Recourse Obligation amount is related to the amountof risk based capital that a PFI must hold for regulatorypurposes for loans delivered under the program The CE Recourse Liability is related to properly accounting forthe loans delivered under the program per Generally AcceptedAccounting Principles42

ACCOUNTING FORRETAINEDSERVICING

MORTGAGE SERVICING RIGHTSAccounting Implications Accounting and reporting for MSRs is set for in FAS ASC 860-50Existence of Servicing – FAS ASC 860-50-25-1 A servicing asset or liability arises each time an institutionundertakes an obligation to service a financial asset by enteringinto a servicing contract in connection with –1. a transfer that meets the requirements for true sale or2. the acquisition or assumption of a servicing obligation notrelated to the financial assets of the servicer44

MORTGAGE SERVICING RIGHTSMSR Asset or Liability – FAS ASC 860-50-30The benefits of the servicing, including the servicing fees, ancillaryincome, float, etc. must exceed “adequate compensation” in order tohave a servicing asset. If not, the servicer has a liability.Adequate compensation includes a profit and is determined by themarketplace. It is based on marketplace costs, not the servicer’s internalcosts.45

MORTGAGE SERVICING RIGHTSInitial Recording Servicing assets and liabilities must be reported separately A servicing asset can become a servicing liability over its life andvice versa46

MORTGAGE SERVICING RIGHTSInitial Recording Record MSR at fair value – quoted price for exact or similar asset would bebest – discounted cash flow can be used in the absence of trade information Industry believes MSRs are Level 2 or Level 3 assets based on a discountedcash flow model Value excess servicing separately - true IOo Creation of the IO does not violate true sale, if part of overall considerationfor the 100% sale of the loan47

MORTGAGE SERVICING RIGHTSHow to Account for the MSR After the Initial Recording FAS ASC paragraph 860-50-35-1 allows the asset to be measuredand reported in one of two ways:1. Fair Value Method2. Amortization Method A servicer can select either method but cannot switchmethodologies unless it moves to the Fair Value method at thebeginning of the fiscal year before interim financial statements havebeen released. A servicer cannot go back to the amortizationmethod after it has elected Fair Value.48

Polling Question #3

MSR AccountingFair Value Method The fair value is determined at each reporting period The asset is adjusted to equal its fair value The difference is taken into income or expense for thatreporting period Institutions that hedge their servicing rights portfolios canbenefit from the fair value method because the accounting isless complex than under FAS ASC Topic 815 – Derivativesand Hedging. Institutions that do not hedge their portfoliosand that elect the fair value method could experienceearnings volatility.50

MSR AccountingAmortization MethodAmortize the MSR in proportion and over the period of estimated net servicingincome (level yield method) and assess servicing assets for impairment based onfair value at each reporting date.51

MSR ImpairmentImpairment Considerations Impairment is best measured at the loan level and is reported at thepredominant risk characteristic stratum There is a difference between temporary impairment, which is accounted forthrough an allowance and permanent impairment, which requires a direct writeoff52

MSR ImpairmentABC Bank Servicing Portfolio as of June 30, 202253

MSR ImpairmentManaging Runoff Risk The operational / macro hedge Hedge with positive convexity instruments Utilize appropriate amortization methodology54

MORTGAGE SERVICING RIGHTSFFIEC Call Report Requirements for MSRs – Form 0411. Total volume of loans sold - Schedule RC-S, item 11A and RC-S,Memoranda, item 2a (with recourse) or item 2b (withoutrecourse)2. Book value of retained servicing – RC-M, Memoranda, item 2a3. Estimated fair value of retained servicing – RC-M, Memoranda,item 2a(1)4. Gain or Loss on loan sales for the quarter should be reported onSchedule RI, item 5i5. Net servicing fees for the quarter should be reported on ScheduleRI, item 5f55

MORTGAGE SERVICING RIGHTSFFIEC Call Report Requirements for Mortgage Banking Activities –Form 041Schedule RC-P – 1-4 Family Residential Mortgage needs to becompleted if the following is true:1. The Bank at which either 1-4 family residential mortgage loanoriginations and purchases for resale from all sources, loan sales,or quarter-end loans held for sale exceed 10 Million for twoconsecutive quarters.56

MORTGAGE SERVICING RIGHTSFFIEC Call Report Requirements for MSRs – Form 0511. Schedule SUItem 5 – Servicing Retained with Recourse – YESItem 5 a. – Outstanding UPB of loans sold with recourseItem 6 – Servicing Retained without Recourse – YESItem 6 a. – Outstanding UPB of loans sold without recourse2. Book value of retained servicing – RC-M, Memoranda, item 2aa.b.c.d.3. Estimated fair value of retained servicing – RC-M, Memoranda,item 2a(1)4. Gain or Loss on loan sales for the quarter should be reported onSchedule RI, item 5i5. Net servicing fees for the quarter should be reported on ScheduleRI, item 5f57

MORTGAGE SERVICING RIGHTSFFIEC Call Report Requirements for MSRs – Form 051Schedule SU – 1-4 Family Residential Mortgage Banking Activities1. Item 2 – For 2 calendar quarters preceding the current quarterdid the institution meet one or both of the following mortgagebanking activity thresholds: 1. Sales of 1-4 family residentialmortgage loans during the calendar quarter exceeded 10million, or 2. 1-4 family residential mortgage loans held for saleor trading as of calendar quarter-end exceeded 10 million?2. Item 2 a. Principal amount of 1-4 family residential mortgageloans sold during the quarter3. Item 2 b. Quarter-end amount of 1-4 family residential mortgageloans held for sale or trading.58

MORTGAGE SERVICING RIGHTSNCUA 5300 Call Report Requirements for MSRs1. Servicing fees are included in Non-Interest Income – Page 5,line 132. Loan servicing expenses are included in Non-Interest Expense –Page 5, line 293. Total amount of 1st mortgage loans sold into the secondarymarket year-to-date is reported on Schedule A, Section 6,Account 7364. Amount of real estate loans sold but serviced by the credit union(dollar amount of servicing) is reported on Schedule A, Section6, Account 779A5. The MSR book value is reported on Page 2, Line 22, Account7796. MSR book value is risk weighted at 250% under the new risk-based capital rule59

Accounting for CreditEnhancement FeesReceivable & CreditEnhancementObligation Liabilities

MORTGAGE PARTNERSHIP FINANCEPROGRAMRecording of the CE Obligation LiabilityRecord the CE Recourse Liability and the CE Fee Receivable at their fair valuesRecord CE Recourse Liability equal to CE Fee Receivable – FAS ASC 460-10Practical Expedient61

MORTGAGE PARTNERSHIP FINANCEPROGRAMFFIEC Call Report Requirements for CE Obligation LiabilityBASEL III “The agencies believe that these exposures that tranche credit risk meet thedefinition of a synthetic securitization and that the risk of such exposures wouldbe appropriately captured under the securitization framework.” (pg. 346)62

MORTGAGE PARTNERSHIP FINANCEPROGRAMCalculating Risk Weight Assets Related to the MPF Program Gross up method under general risk-based capital rules Simplified Supervisory Formula Approach (SSFA) Multiply the CE Obligation by 12.5 (dollar for dollar capitalimpact) Supervisory Formula Approach (SFA) (for largestinstitutions only – advanced approaches)The SSFA and gross up method approaches are subject to arisk-weighted assets floor of 20%63

MORTGAGE PARTNERSHIP FINANCEPROGRAMMaster Commitment Detail Report64

MORTGAGE PARTNERSHIP FINANCEPROGRAMGross-Up Method – Five Inputs Pro-rata share – for MPF CE obligation 100% Exposure amount – CE obligation amount Enhanced amount – Balance of sold loans in excess of the CE obligationamount Applicable risk weight – 50% for loans that are current and 100% for non-current loans First Loss Account – The amount of the FLA is deducted beforemultiplying the balance by the Applicable Risk Weight resultIf a bank elects the gross-up method, it must use it for all of its securitizationexposures.65

MORTGAGE PARTNERSHIP FINANCEPROGRAMGross-Up Method – Calculation Example Pro-rata share – 100% Outstanding Amount – 42,669,125 Exposure amount – CE obligation amount - 298,693 First Loss Account amount - 442,822 Enhanced amount – Balance of sold loans in excess of the CEobligation amount – 42,370,432 Delinquent loans – 640,037 (1.50%) Applicable risk weight – 50% for loans that are current and 100%for non-current loans – (1 - 1.50%)*0.5 1.50% 50.75% Risk Weighted Assets 50.75% * ( 42,669,125 - 442,822) or 21,429,84966

MORTGAGE PARTNERSHIP FINANCEPROGRAMSSFA Method – lculator-2/67

MORTGAGE PARTNERSHIP FINANCEPROGRAMGross-Up Method – Pros & ConsPros:Cons:1. Benefits MCs with1. Calculations should behigh CE balancesand low DQs.2. RWA should benefitas UPBs decrease3. Easier calculationthan the SSFAMethod68done at the MC level.2. PFI must use Gross-UpMethod for all MCs

MORTGAGE PARTNERSHIP FINANCEPROGRAMSSFA Method – Pros & ConsPros:Cons:1. Benefits MCs with1. Not “Simple”high FLA balances.2. RWA should benefitas UPBs decrease692. Calculations should bedone at the MC Level

MORTGAGE PARTNERSHIP FINANCEPROGRAMRisk Weight Capital For any individual Master Commitment, if multiplying the CEObligation amount by 12.5 is a better result than either the SSFA orGross-up method, the institution can hold dollar for dollar capital forsaid Master Commitment. An institution will report the most beneficial result to risk-basedassets in RC-R line 10. See “Guide to Reporting Under Basel III for FHLB MPF ProgramParticipants” document on the Wilary Winn website for specificsabout RC-R reporting.70

MORTGAGE PARTNERSHIP FINANCEPROGRAMCommunity Bank Leverage Ratio (CBLR) The Community Bank Leverage Ratio could potentially benefitMPF participants. The rule replaces risk-based capital with asimple leverage ratio for “eligible” community banks. Eligiblebanks would thus not have to consider the off-balance sheetexposure arising from the CE obligations in calculating requiredregulatory capital. However, the proposed rule limits the amountof MSAs and off-balance sheet exposures in order to be deemedeligible to use the leverage ratio. Wilary Winn has published a summary of the Community BankLeverage Ratio rule on its website.71

MORTGAGE PARTNERSHIP FINANCEPROGRAMComplex Credit Union Leverage Ratio (CCULR) The Complex Credit Union Leverage Ratio rule replaces risk-basedcapital with a simple leverage ratio for “eligible” credit unions( 500M in total assets). PFIs opting into the CCULR would nolonger calculate the risk-weighted ratio in accordance with the 2015risk-based capital rule. Under that rule, for loans transferred underthe FHLB’s MPF program, applying a 20 percent credit conversionfactor to the net outstanding loans balance and then applying a 50percent risk weight results in a risk-based capital requirement of10% of the outstanding UPB of the commitments. For credit union’s looking to adopt the CCULR, it must report theoutstanding loan balance amount as an off-balance sheetsecuritization. Total combined off-balance sheet exposures cannotexceed 25 percent of total assets.72

MORTGAGE SERVICING RIGHTSHow Wilary Winn Can Help1. Wilary Winn can perform a valuation of a servicer’s entire mortgage servicingportfolio. The valuation will include determining the values of the MSR at theLoan Level and assisting with any questions related to the accounting for theportfolio. Similarly, we can calculate the value of the CE Fees Receivableand CE Obligation Liability at the loan level. We can also help you calculatethe amount of risk-weighted assets your bank must hold related the CERecourse Obligation Amount.2. For those electing the amortization method for MSRs, Wilary Winn willincorporate the MSR into a loan level basis roll forward file, which providesthe information necessary to produce the amortization journal entries goingforward. The file includes a section where newly sold loans can be addedand the amount of the new MSR is calculated; the amortization for theseloans is also calculated. We can also provide similar ongoing accountingrelated the CE Fees Receivable and CE Obligation Liability.73

RESOURCESWebsitehttps://wilwinn.com/resources/74

CONTACT USServices and Main ContactsAsset Liability Management, Capital Stress Testing, Concentration Risk Analyses, ALM Validations and CECL:Joe Trabantjtrabant@wilwinn.comMike Tessiermtessier@wilwinn.comMatt Ericksonmerickson@wilwinn.comServicing Rights and Mortgage Banking Derivatives:Anneliese Raminaramin@wilwinn.comEric Nokkenenokken@wilwinn.comMergers & Acquisitions and Goodwill Impairment Testing:Cole Schultecschulte@wilwinn.comMatt Ericksonmerickson@wilwinn.comNon-agency MBS, ASC 310-30, TDRs and Trust Preferred Securities:75Cole Schultecschulte@wilwinn.comAnneliese Raminaramin@wilwinn.comFrank Wilaryfwilary@wilwinn.com

Federal Home Loan Bank Des Moines Eric Nokken, Director Anneliese Ramin, Senior Manager Wilary Winn LLC August 23, 2022. 2 . FHLB/FNMA/FHLMC cash window MBS TBAs MBS Assignment of Trade (AOTs) . Rates Loan Rates Loan Loan Increase Has Been Drop Has Been at Inception 50 bp Processed 100 bp Approved Close

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