Nationstar Mortgage Holdings reported a net loss of $48 million, or $0.53 per share, for the first quarter of 2015 compared with a net income of $19 million ($0.21 per share) for the previous quarter, according to an announcement from the Lewisville, Texas-based residential mortgage servicer on Tuesday morning.

Derivative losses were largely responsible for dropping Freddie Mac's net income by nearly $2 billion from Q3 to Q4 down to $227 million, but the GSE responded by nearly doubling that net income total in Q1 to $524 million. It marked the 14th consecutive quarter of profitability for Freddie Mac. In Q1, derivative losses declined to $2.4 billion, down from $3.4 billion the previous quarter.

Fitch Ratings affirmed that while Fannie Mae and Freddie Mac maintained a "Stable Rating Outlook" in April due to direct financial support from the U.S. government, the ratings company said it expected the controversial FHFA's conservatorship of the two Enterprises would continue indefinitely.

The U.S. Court of Appeals for the District of Columbia Circuit dismissed a constitutional challenge to the Consumer Financial Protection Bureau (CFPB) brought about by Costa Mesa, California-based support services company Morgan Drexen Integrated Systems.

Freddie Mac reported a net income of $227 million for the fourth quarter of 2014, a decline of $1.9 billion from the third quarter. The GSE attributed the drop in net income to derivative losses, which totaled $3.4 billion for the quarter driven by declining interest rates.

Both the total bankruptcy filings for April and that average filings per day declined from March in the same number of filing days, continuing a trend that has been ongoing since the height of the financial crisis in 2010, according to April 2015 AACER bankruptcy data reported by Epiq Systems. In April, there were 77,884 total bankruptcy filings, down from March's total of 81,622 in the same number of filing days (22) during the month. April totaled 3,540 filings per day, compared with 3,712 in March.

The data showed that modification, collection, and foreclosure-related complaints were falling at an even fast rate than the number of non-current loans over that same period. In Q1 2013, the number of such complaints were received by the Bureau totaled 10,047; for the fourth quarter of 2014, that number was 4,741, a decline of 53 percent–compared to the 27 percent decline for non-current loan inventory.

The number of residential mortgage borrowers in a negative equity position during January 2015 was reported at slightly more than four million, which is a decline of 29 percent from the same period in 2014, according to Black Knight's March 2015 Mortgage Monitor released Monday.

The U.S. Department of Housing and Urban Development (HUD) has issued a memo announcing the rescinding of a mortgagee letter written in January that would have allowed reverse mortgage lenders the option of delaying foreclosure proceedings on surviving non-borrowing spouses.

Counsel's Corner is an ongoing series in which DS News talks with default servicing attorneys around the country about the most pressing issues facing the default servicing industry. This installment features Marlon Bates of Salt Lake City-based Scalley Reading Bates Hansen & Rasmussen.