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84 84 INVESTMENT PROPERTY PRESERVATION TECH FITCH IDENTIFIES HIGH DILIGENCE IN RMBS Residential Mortgage-Backed Securities (RMBS) diligence has remained high, according to new data from Fitch Ratings. e latest Fitch Ratings Diligence Market Update showed that private-label RMBS transactions issued in recent years have typically included more loan-level due diligence than the sample size minimums required in rating agency criteria. Most prime jumbo, nonprime and re-performing loan (RPL) transactions have provided due diligence reviews on close to 100% of the mortgage pool. e report includes an updated list of Fitch "Acceptable" TPR firms along with newly released tiers. Fitch tiers Acceptable TPRs as 1, 2, or 3 with "1" being the highest. According to Fitch Ratings, the 2017 Tax Cuts and Jobs Act (the Act), which limits state and local tax (SALT) deductions and reduces the amount of housing debt eligible for interest deduction, may have exacerbated slowing home price growth in certain areas. Fitch's rating analysis for residential mortgage backed securities takes into account these declines in both its base case and stress scenarios. Rising mortgage rates at YE 2018 and a larger inventory of high-priced homes are contributing factors to slowing home price growth; however, these two factors alone cannot fully explain the slowing price growth and price declines observed in the areas where SALT deduction amounts and usage was highest prior to the tax code change. SALT deductions cap property, income, vehicle, and sales tax itemized deductions to a maximum of $10,000, and lowers the housing debt amount eligible for mortgage interest deduction, meaning that high-income taxpayers are most affected by the change in the SALT deduction. In tax year 2017, more than 60% of taxpayers who earned more than $100,000 claimed a SALT deduction compared with about 10% of those who earned below $50,000. e average SALT deduction amount was also significantly higher for high-income taxpayers than low-income taxpayers. "Since early 2018, states with higher property taxes have seen acute home price appreciation slowdown and even price declines in several metropolitan areas," Fitch said. "Congressional district level data shows that districts where the real estate SALT deduction was more often pursued and the deduction amount averaged higher in the tax year of 2017, prior to the change in SALT deductibility, have seen more noticeable slowing in home price growth over the past year." Journal