Capital Requirements for Non-Bank Mortgage Companies

13 Pages Posted: 9 Jun 2014

See all articles by Richard Christopher Whalen

Richard Christopher Whalen

Whalen Global Advisors LLC; Mortgage Bankers Association; National Mortgage News; FINRA

Marjan Riggi

Kroll Bond Rating Agency

Date Written: May 28, 2014


Federal and state regulators are currently considering the imposition of capital requirements and other prudential rules on various classes of non-bank financial institutions, including insurers and mortgage servicers. This report examines some of the issues involving non-bank financial companies with a focus on non-bank loan mortgage originators and/or servicers (“seller/servicers”) in the context of the evolving discussion among regulators and researchers toward developing “appropriate” regulation and supervision like that traditionally applied to insured depository institutions (IDIs).

Keywords: Capital Requirements, Non-bank, Mortgage Servicer, Lender, True Sale, Fraud

JEL Classification: G18, G21, G38, K23, K22, L50, L51, N20

Suggested Citation

Whalen, Richard Christopher and Riggi, Marjan, Capital Requirements for Non-Bank Mortgage Companies (May 28, 2014). Available at SSRN: or

Richard Christopher Whalen (Contact Author)

Whalen Global Advisors LLC ( email )

P.O. BOX 8903
BRIARCLIFF MANOR, NY New York 10510-8903
United States
914-645-5304 (Phone)


Mortgage Bankers Association ( email )

1919 Pennsylvania Ave
NW Washington, DC 20006-3404
United States

National Mortgage News ( email )

One State Street Plaza, 27th Floor
New York, NY New York County 10004
United States

HOME PAGE: http://

FINRA ( email )

1735 K Street NW
Washington DC, DC 20006
United States

Marjan Riggi

Kroll Bond Rating Agency ( email )

845 Third Avenue
Fourth Floor
New York, NY 10022
United States

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