Do Nonbank Mortgage Companies Pose Systemic Risk to the US Economy?

14 Pages Posted: 10 Feb 2020

See all articles by Richard Christopher Whalen

Richard Christopher Whalen

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

Date Written: January 15, 2020


This working paper reviews the work of the Financial Stability Oversight Council (FSOC) in terms of identifying potential systemic risk in the nonbank sector under authority from the Dodd-Frank Wall Street Reform Act of 2010. We discuss past efforts by the agencies represented within the FSOC to impose capital requirements on nonbank financial institutions such as insurers, mortgage lenders and servicers. The FSOC Annual Report issued in 2019 is then reviewed and assessed. Finally, recommendations are made to assist the FSOC in better understanding the systemic risks, if any, posed by nonbank companies engaged in lending and loan servicing.

Keywords: mortgage lending, mortgage servicing, nonbanks, FSOC, Federal Reserve, MetLife, systemic risk, mortgage servicing rights, banks

JEL Classification: G00, G20, G23, G32, G33, G38, K2, K23, M2, M48, N2

Suggested Citation

Whalen, Richard Christopher, Do Nonbank Mortgage Companies Pose Systemic Risk to the US Economy? (January 15, 2020). 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 )

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National Mortgage News ( email )

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New York, NY New York County 10004
United States

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FINRA ( email )

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Washington DC, DC 20006
United States

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