E3

Resources

Secondary market and servicing

2 pieces.

All writing
FIGURE 1Two estimates of the non-QM market, not reconciledUS originations, 2025. Neither figure is wrong; they measure different things.Falls outside the Qualified Mortgage standarda regulatory boundary set by Regulation Z$239bn~10% of all US originationsOriginated and aggregated for non-QM securitisationa funding-channel definition; excludes portfolio lending$108bn$131bn apart — the cause is unverifiedPolygon publishes an HMDA-based method. The Bank of America method has not been obtained, so the gap is a hypothesis.Compliance requirements attach at the regulatory boundary, not at the funding channel.

Non-QM Is Now Roughly One Loan in Ten. Nobody Agrees How Big That Is.

Bank-statement, DSCR and asset-depletion review in practice — with the market-sizing disagreement kept in a clearly qualified sidebar.

6 min readFIGURE 1Adding to the file gets harder as scrutiny risesIt never reaches zero: correction remains possible under the remedies framework.ClosingDeliverySecuritisationServicing transferEPD / reviewDemandEASE OF ADDING TO THE FILESCRUTINY APPLIEDadding becomes a remedy processand starts being evidenceCorrection remains possible after delivery. What is hardest to recover later is the reasoning nobody recorded at the time.Milliman Mortgage Repurchase Index Q4 2025 — a MODELLED estimate of lifetime repurchase risk, not observed buybacks: Fannie Mae 0.173%, Freddie Mac 0.260%.

After Closing, a File Can Still Be Corrected — Within Limits

Closing does not freeze the file. What can still be corrected, reverified or appealed after delivery — and the limits on later evidence.

6 min read