Avoiding the pitfalls of warehouse lending

January 10, 2023

In the mortgage warehouse lending and repurchase space, risk can never be fully removed – but it can be mitigated. Learn how the right document custodian can help you manage your warehouse lending facilities and effectively sidestep a variety of obstacles.


Risk management, by necessity, should be top of mind for finance professionals. In this article, we’ll discuss how partnering with the right custodian can help you bypass many of the potential risks associated with mortgage warehouse and repurchase operations.


What does a custodian do?

The duty of a document custodian is to receive, verify, store and release documents that act as underlying collateral for some form of debt encumbrance or instrument. Custodians operate by an overriding “golden rule” taken from the laws of physics: just as no two particles of matter can occupy the same space, no single collateral file can have more than one owner.

While a custodian’s role may sound basic, it’s critical to the market. For scale, Ginnie Mae mortgage-backed securities (MBS) issuance totaled more than $360 billion through July 2022, and each one of those loans is backed by a mortgage note held in a custodian’s vault. 

Warehouse and mortgage repurchase obligation facilities rely on custody services but require more intensive daily interactions than many other clients. Large securitization platforms and agency sale conduits typically manage their business in days, whereas warehouse and repurchase facilities do it in hours. Custodial document reviews accommodate the necessary certification requirements. They can also drive borrowing base calculations and interest payments between “wet” loans, where funds are disbursed before document completion, or “dry” loans, where the mortgage documents are received and reviewed after the loan closing.

Custodians provide daily or more frequent reporting on their activities to all counterparties associated with warehouse lending transactions. They ensure collateral is delivered to third parties under the possession of a bailee to avoid jeopardizing a lender’s or purchaser’s security interests. They may also act as the certification agent for loans being sold to an agency under their cash or MBS purchase programs.


What should you look for in a custodian? 

Your custodian is one of your most important strategic industry partners. They should thoroughly understand where your business is today and – more importantly – where it’s heading in the future.

A strong partner draws on the full resources of its organization to work with you toward a common goal for success. Skillful communication is key to this relationship, and it’s an attribute you should expect them to prioritize.

In the U.S., most custodians are regulated by a federal body, such as the Office of the Comptroller of Currency. This regulatory oversight requires the organization to apply certain controls and maintain policies and procedures to adhere to rules and regulations for operating in this capacity. Customers that work with top-tier custodians can benefit from the strong control infrastructure, rigorous training and comprehensive risk practices they apply to their entire organization.

“Custodians operate by an overriding 'golden rule' taken from the laws of physics: just as no two particles of matter can occupy the same space, no single collateral file can have more than one owner.”

How do custodians differ?

Not all custodians provide the same services. Many focus primarily on servicing the portfolio of their internal loan department – and maybe, on occasion, moonlight as a service provider to third parties.

While it’s easy to obtain a list of approved agency custodians, few listed usually have experience servicing the specific needs of a warehouse or mortgage repurchase provider. Although many of the baseline functions seem the same, the purpose, impact and cycle-time requirements for a warehouse or repurchase facility are unique. Your custodian must understand those requirements and demonstrate their understanding through their approach.

Usually, warehouse custodians also offer a broader complement of services, such as disbursement agent and administration services, for deeper back- and middle-office coverage.


How can custodians help manage risk?

Borrowing base monitoring and pipeline management provide the lifeblood of warehouse and mortgage repurchase facilities. As such, the risk of fraud (e.g., document, counterparty, wire) is a constant variable through the lifecycle of a transaction.

While risk can never be fully removed, it can be mitigated. Warehouse custodians specialize in other services that help reduce those risks:

  • Systematic and operational controls can prevent double pledging of collateral within single or multiple facilities.
  • Disbursement agent services can direct wires to closing agents for wet funded loans. Typically, this will also include depository oversight and controls when the custodian is also the account bank (i.e., OFAC testing).
  • Dedicated document custody professionals have experience with warehouse custody transactions.
  • Serving as the MBS settlement agent can facilitate agency take outs and gestation repurchase trades.
  • Administrative services can supplement and enhance borrowing base mechanics through collateral pricing, concentration reporting and margin maintenance.

Not all programs or facilities require all services, but they do all need a trusted partner. Due diligence is important to ensure you have the best fit for your needs. When your warehouse custodian serves as your strategic partner, they can help you position your business for success today and into the future.


At U.S. Bank, we’re committed to serving as your trusted partner by offering a variety of products and services that help you mitigate risk while adding value to your business. Learn more about our document custody solutions and the services we offer.

Related content

10 ways a global custodian can support your growth

Fight the battle against payments fraud

Fraud prevention checklist

How to keep your assets safe

The benefits of a full-service warehouse custodian

3 tips to maintain flexibility in supply chain management

Liquidity management: A renewed focus for European funds

Proactive ways to fight vendor fraud

Business risk management for owners of small companies

Avoiding the pitfalls of warehouse lending

5 Ways to protect your government agency from payment fraud

How to improve your business network security

The latest on cybersecurity: Mobile fraud and privacy concerns

Complying with changes in fund regulations

What is CSDR, and how will you be affected?

Cybersecurity – Protecting client data through industry best practices

Government agency credit card programs and PCI compliance

Post-pandemic fraud prevention lessons for local governments

Risk management strategies for foreign exchange hedging

Best practices on securing cardholder data

Turn risk into opportunity with supply chain finance

Cybercrisis management: Are you ready to respond?

White Castle optimizes payment transactions

Webinar: Approaching international payment strategies in today’s unpredictable markets.

Evaluating interest rate risk creating risk management strategy

Increase working capital with Commercial Card Optimization

The surprising truth about corporate cards

Automate accounts payable to optimize revenue and payments

How to improve digital payments security for your health system

5 questions you should ask your custodian about outsourcing

Alternative investments: How to track returns and meet your goals

Protecting cash balances with sweep vehicles

Manufacturing: 6 supply chain optimization strategies

Keep your finances safe and secure: Essential tips for preventing check fraud

How to spot an online scam

What is financial fraud?

Authenticating cardholder data reduce e-commerce fraud

Mobile banking tips for smarter and safer online banking

Why Know Your Customer (KYC) — for organizations

Webinar: CRE technology trends

Healthcare marketing: How to promote your medical practice

Small business growth: 6 strategies for scaling your business

Why a mobile banking app is a ‘must have’ for your next vacation

Money muling 101: Recognizing and avoiding this increasingly common scam

How-to guide: What to do if your identity is stolen

Learn to spot and protect yourself from common student scams

The password: Enhancing security and usability

BEC: Recognize a scam

Hospitals face cybersecurity risks in surprising new ways

4 ways to outsmart your smart device

Webinar: How to stay safe from cyberfraud

Webinar: Robotic process automation

Webinar: CRE Digital Transformation – Balancing Digitization with cybersecurity risk

Hospitals face cybersecurity risks in surprising new ways

Webinar: CRE Digital Transformation – Balancing Digitization with cybersecurity risk

BEC and deepfake fraud

How you can prevent identity theft

Evaluating interest rate risk creating risk management strategy

Authenticating cardholder data reduce e-commerce fraud

Start of disclosure content

Loan approval is subject to credit approval and program guidelines. Not all loan programs are available in all states for all loan amounts. Interest rates and program terms are subject to change without notice. Mortgage, home equity and credit products are offered by U.S. Bank National Association. Deposit products are offered by U.S. Bank National Association. Member FDIC.